This presentation explains the First Amendment jury instruction for evidence of retaliation. We use this in employment law cases in which clients have been retaliated against. It sets forth what we must prove and helps juries assess whether we have met our burden.

We continually tell juries that enjoyment of life is all we really have. When that is taken away, victims must be compensated. This chart explains the federal jury instruction and helps juries put a value on an extremely significant item of damage.

This series of slides reiterates to the jury the elements we must prove to establish a claim for hostile work environment. By using this along with closing arguments we make it clear to the jury that we have established such a claim.

Each case is unique. We take the key facts or pieces of evidence in a case and highlight them in a chart that reinforces them for the jury. This powerful chart, which was placed on a board 4½ feet tall, detailed for the jury in Morgan v. Amtrak the persistent and intolerable discrimination suffered by Mr.

We frequently use charts at trial to emphasize key points of law to the jury. We refer to the charts throughout trial and particularly during closing arguments when the jury is assessing the evidence. This chart details what is required to establish a punitive damages claim under federal law.

In every case, we provide the jury with a detailed report of economic damages suffered by our client. We then summarize the damages in a chart to provide the jury guidance in assessing a damage award. We used this particular chart in Morgan v. Amtrak, in which our client suffered persistent on-the-job racial discrimination. After a successful appeal to the U.S. Supreme Court and a new trial, a jury awarded Mr. Morgan $500,000.