Wednesday, January 28, 2015


FIRST RECESS  Model Jury charge NJ Criminal cases

(This instruction should be given just before the first break during jury selection and repeated for each new panel before their first break)

 In a few minutes you will be excused for a short break.  I instruct that you must not discuss this case among yourselves or with anyone else during this or any other recess. 
            No one is permitted to talk to you about this case outside the courtroom.  If you should see any of the attorneys or parties and they do not greet you, do not be offended or think that they are being rude.  They are not permitted to talk to you.  If anyone approaches you and tries to talk about this case report that to me or my staff immediately without discussing it with your fellow jurors.  Do NOT discuss anything about this case with your fellow jurors until I instruct you to do so at the end of the case after you have heard all of the evidence produced in this courtroom, heard the summations of the lawyers, heard my instructions to you about the law.  Once I instruct you to begin your deliberations in the privacy of the jury room that will be the first time you can discuss this case. You may NOT have any discussions with anyone before then about this case.
            During this or any other recess, or when you go home at the end of the day, I instruct you NOT to discuss this case with anyone such as your fellow jurors, friends, co-workers or family members.  Do NOT text them, phone them, e-mail them, tweet them about this case by any means either in person or by any electronic means.  Every conversation about a jury trial begins with just a single sentence no matter how innocent.  If you start talking about this trial with someone else, that person will say something that might affect your thinking about the facts of this case.  That would obviously be unfair to both parties in this case because what some other person says outside this courtroom is NOT evidence in this case.
            I instruct you not to read or have anyone read to you any newspaper accounts or search the internet for any media accounts about this trial or read or have anyone read to you or search the Internet for blogs, tweets or Facebook pages about any persons, topics or places related to this case.  I also instruct you not to visit the scene(s) of the incident(s) or try to view (it/them) on the Internet through Mapquest or Google Earth type sites.  Do not do any legal or factual research about anyone or any topic connected to this case.  You are NOT here as investigators.
            If you are sworn as jurors in this case, you will become the sole judges of the facts, so you must remain impartial throughout the trial.  You must decide the facts of this case solely from the evidence produced in this courtroom and NOTHING ELSE.  It would be unfair and a violation of your oath as jurors to base your decision about the facts of this case upon something that was said to you or discovered by you outside this courtroom.