PHILANDO CASTILE CASE: The 60 questions potential Yanez trial jurors must answer

For potential jurors in the Jeronimo Yanez trial, Tuesday may have felt more like school than court. Men and women spent much of the day answering 60 questions in the Juror Questionnaire.

Lawyers will use the answers to decide who they might want on or off the jury, and what questions they may want to ask directly to the potential jurors on Wednesday.

Christina Marinakis, the director of jury research for Litigation Insights, a jury consulting business not involved in this case, spoke with Fox 9.

“One of the key questions on the juror questionnaire is the juror's opinion of law enforcement and their experiences with law enforcement. Given the political climate right now, and the Black Lives Matter movement, it’s really important for attorneys on both sides to find out what their position is on those issues because that’s how the jurors will view the evidence in this case,” said Marinakis, who has a J.D. and Psy.D.

Determining a potential juror’s possible bias is difficult, Marinakis says, because the jurors may not even realize they have a bias. Thus, the Questionnaire is designed to expose possible bias through questions about where they get their news, and what hobbies they enjoy.

“One of the questions on the Questionnaire is 'What hobbies are you involved in?' and 'What TV shows do you like?' she said. "Those may seem like unimportant questions, but what it gets at is what are the things that a juror is likely to attend to. Are they more interested in law and order and the police conduct? Or are they more interested in following cases like ‘Making a Murderer’ where a suspect is wrongfully accused?”

Marinakis said lawyers are almost certainly pouring through jurors’ social media accounts to ascertain details like their political affiliations.

On Wednesday, lawyers will get to talk directly with the potential jurors.

“The way a person responds is just as important as what they write," she said. "So you’re looking at body language. Does the person appear like they want to serve? Sometimes you have a person who is really trying hard to answer the right questions that they may be hiding something, might have agenda they’re trying to advance forward,” Marinakis said.

Lawyers may also consider how potential jurors treat each other—who might be a leader and who might be a follower.

To help the jurors consider their own biases, Marinakis said, lawyers often resort to analogies. She suggested asking potential jurors to ponder whether they could fairly referee a Super Bowl game involving the Vikings.


General background

1.  Age ____

2. Gender: ____ Male  ____ Female

3. What city / town / neighborhood / township do you live in? ________

4. How long have you lived in Ramsey County? ________

5. How long have you lived at your current address? ________

____ Own ____ Rent

6. Where did you grow up? (City, County, State) ________

7. What is your marital status?

____ Married. How many years? ____

____ Divorced. How long were you married? ____

____ Separated. How long? ____

____ Widowed. How long were you married? ____

____ Living with significant other. How long? ____

____ Single

8. If you have children, stepchildren or are the guardian of any children, please state: Sex, age, does child live with you, *education, *occupation, *marital status. Answers to questions marked with an * are only required for adult children.

9. If anyone else is living in your home, what is their relationship to you, their age and occupation?


10. What is your present job or occupation? ________

____ Full Time ____ Part Time

____ Unemployed ____ Disabled

____ Retired ____Homemaker


11. Briefly describe your job: ________

12. How long have you been so employed? ____

13. Prior to this employment, what did you do? ________

14. If you are retired or disabled, what was your last job or occupation? ________

15. If you are currently unemployed, what is your customary work? ________

16. Do / did you supervise others? ____ Yes ____ No

17. Have you ever owned your own business? ____ Yes ____ No

IF YES, please describe nature of the business: _________

18. If married or living with another person, does the other person work outside the residence
and, if so, what is that person's job or occupation? ________

19. If he or she is retired or unemployed, what was his or her occupation before retiring or being unemployed? ________


20. What is your highest level of education?

____ Less than high school ____ College work ____ Graduate degree

____ High school diploma ____College graduate

____Technical or business school ____Postgraduate work

WHEN AND FROM WHAT INSTITUTION: _______________________

21. If married or living with another person, what is your spouse or significant other's educational background? __________

22. Have you ever had any training, education or iobs or have you ever done any volunteer work in any of the following areas? (Check each one that applies to you)

____Corrections / Jail / Prison

____Victims of Crimes


____Firearms / Guns

____Forensic Sciences


____Genetics / DNA


____Justice System / Courts

____TV / Radio



____Law Enforcement

____Local / State Government

____Medicine / Nursing

____Mental Health


____Police Procedures


____Science or Biology

IF YES TO ANY OF THESE, please explain: ______________


23. It is anticipated that this trial will begin on May 30,2017, and could take up to three weeks to complete. Do you have any personal obligations, circumstances or commitments that would impact your ability to serve on this jury? ____Yes ____No

IF YES, please explain: _____________

24. What are your hobbies, major interests, recreational pastimes, and spare-time activities?

25. Please list all groups or orgarrizations in which you participate or are a member. For example, service clubs, civic groups, social groups, church or church groups, unions or professional organizations, volunteer activities, educational or political groups, neighborhood groups or self-help groups, the NRA, Sierra Club, PTA, Rotary, any group  that protests against police or government agencies, any group whose members are primarily composed of persons of one race, any group which discriminates against any race, any group which claims superiority over other races: _______________________

26. Have you ever held a leadership position in any organization listed in response to the previous question? ____Yes ____No

IF YES, please list the leadership position(s) and duties:

27. Where do you get your news? Check all that apply:

____Radio ____Facebook

____Newspapers ____Twitter

____Television ____LinkedIn

____Magazine ____Other Social Media (please identify) ____



____Other (please identify) ________

28. How often do you read the newspapers to get your news? Please check one box:


____3 to 4 times a week

____7 to 2 times a week



29. How often do you watch television to get your news? Please check one box:


____3 to 4 times a week

____7 to 2 times a week



30. How often do you listen to the radio to get your news? Please check one box:


____3 to 4 times a week

____7 to 2 times a week



31. How often do you search the lnternet or social media to get your news? Please check one box:


____3 to 4 times a week

____7 to 2 times a week



32. Which newspapers or magazines do you regularly read? _________

33. What kinds of television shows, if any, do you watch on a regular basis? (Please check all that apply.)

____Morning news shows like "Good Morning America" and "Today."

____Morning talk shows

____Morning or afternoon soap operas

____Afternoon talk shows

____Evening network news

____Evening or late night local news

____T.V. tabloids like "Hard Copy," "Inside Edition," and "American Journal."

____Prime time series (sitcoms and dramas)

____Reality shows (such as 'Survivor")

____Learning / Discovery / Educational

____Sports / sporting events

____Investigative journalism (like " 20/20," "Dateline, " and "60 Minutes")

____Crime Shows (like "Cops," and "America's Most Wanted")

____Fictional crime stories (such as "CSI," "Law and Order")

____Political talk shows

____Late night news shows

____Late night talk shows (like "David Letterman" or the "Tonight Show")

____Court T.V., CNBC or other court or law related programs


34. Were you ever in the military? (Including ROTC, National Guard) ____Yes ____No

IF YES, answer the following:

a.) What branch? ________

b.) Date of Service? ________

c.) Rate or rank? ________

d.) Where were you stationed? ________

e.) Character of discharge (honorable, general, etc.)? ________

f.) Reason for discharge? ________

g.) What were your duties? ________

h) Were you ever involved in combat? (if yes, when and where) ________

35. If you were in the military, were you ever involved in any way with military law enforcement, non-judicial punishment, courts martial, or administrative boards or hearings? ____Yes ____No

IF YES, please explain: _____________


36. Do you, or any members of your family, own firearms? ____Yes ____No

37. Have you, or any member of your household, ever been a member of, or contributed to, any organization concerned with hunting or firearms, whether for or against such activities? Examples include, but are not limited to the NRA, Ducks Unlimited, Pheasants Forever, etc? ____Yes ____No

38. Have you ever had training in the use of firearm? ____Yes ____No

Law enforcement and judicial contacts

39. Have you, a family member or a close friend, ever been the victim of a crime whether it was reported to law enforcement authorities or not? ____Yes, I have _____Yes, family or friend ____No

IF YES: What was the crime and what was the outcome? ____________

40. Have you ever been a witness to a crime, filed a report with a police office or other law enforcement agency, or had contact with a district or county attorney's office? ____Yes ____No

IF YES, please explain: ____________

41. Have you, any family member, or anyone close to you ever been a suspect in, arrested for, or charged with a criminal of[ense, other than a minor traffic offense? ____Yes ____No

IF YES, please explain: ____________

42. If you answered yes to questions 39r 40, or 41, was there anything about your experiences with law enforcement, attorneys, or the court system that you thought was unfair or unpleasant or not handled appropriately? ____Yes ____No

IF YES, please explain: ____________

43. Tell us about your best or worst experience with law enforcement. _____________

44. There will be law enforcement testimony in this trial. Do you feel that you would give the testimony of police officers any more or less credibility than the testimony of any other witness simply because of their occupation? ____Yes ____No

IF YES, please explain: ___________

45. Have you ever testified in a criminal case as a witness? ____Yes ____No

IF YES, please explain: ____________

46. Do you have any family members or close friends who are employed with a law enforcement agency or our court system? ____Yes ____No

IF YES, please explain: ____________

Prior jury experience

47. Have you ever served on a jury before? ____Yes ____No

IF YES: Please answer the following.

State court ____ Number of times ____ Date ____

Federal court ____ Number of times ____ Date ____

Civil case ____ Number of times ____ Date ____

Criminal case ____ Number of times ____ Date ____

How many times did you deliberate and reach a verdict? _____

Were you ever a foreperson? ____Yes ____No

Was there anything about your prior jury experience that makes you wonder whether you could fairly and impartially act as a juror in this case? ____Yes ____No

IF YES, please explain: ____________

Trial publicity

The defendant in this case, Officer Jeronimo Yanez, is charged with Manslaughter in the Second Degree for the death of Philando Castile in Falcon Heights, Minnesota, on July 6,2016. He is also charged with two counts of Dangerous Discharge of a Firearm from the same incident, endangering Diamond Reynolds and a minor. Officer Yanez has pled not guilty and is presumed to be innocent of each of these charges unless and until he has been proven guilty beyond a reasonable doubt under the facts and law to be applied.

48. If you have heard about this case from television, radio, newspapers, magazines, the Internet, social media or other sources, please check those sources listed below that reflect the source of your information.

____Television ____Tabloids ____Radio ____Internet ____Newspapers

____Internet Chat Rooms ____Magazine ____Family and Friends

____Facebook ____Twitter ____LinkedIn

____Any Other Social Media (please identify) ____________

49. How would you describe the amount of media and other coverage that has come to your attention about this case?

_____I believe I know exactly what happened in this case.

_____A great deal

_____Quite a bit (read many articles or TV stories)

_____Moderate amount (just basic coverage)

____Little (basically, just heard about it)

____None (never heard of this case)

50. What, if anything, do you remember reading or hearing about this case? Please be specific. _____________

51. If you have heard about this case, what sticks out in your mind about what you read, heard, or saw about Philando Castile, the person who was shot? ________

52. If you have heard about this case, what sticks out in your mind about what you read, heard or saw about Diamond Reynolds, the person who is alleged to have been endangered? _________

53. If you have heard about this case, what sticks out in your mind about what you read, heard or saw about Officer Jeronimo Yanez, the defendant? _________

54. Have you had any conversations with family members, friends, co-workers, or other people you know about this case? ____Yes ____No

IF YOU ANSWERED YES, have any of those people ever expressed to you an opinion on the guilt or innocence of Officer Yanez in this case? ____No ____Yes

IF YOU ANSWERED YES, have you ever expressed an opinion on the guilt or innocence of Officer Yanez in this case? ____No ____Yes

Interested parties and attorneys involved in the case

55. Have you ever known or met Officer Jeronimo Yanez, any members of the Saint Anthony Police Department, any Agent or Employee of the Bureau of Criminal Apprehension, Philando Castile, Diamond Reynolds, any of their family, friends, or anyone else who has personal or first hand information about this situation or was involved in any way? ___Yes ___No

IF YES, please explain: ____________

56. The state is represented in this case by Assistant County Attorneys Richard Dusterhoft, Clayton Robinson and Jeffrey Paulsen. The defendant is represented by attorneys Thomas Kelly, Paul Engh and Earl Gray. Do you know any of these attorneys? ___Yes ___No

IF YES, please identify the attorney(s) you know and your relationship or knowledge of them: _____________

Concluding questions

57. During the course of this trial you will be instructed by the judge as to the relevant law which you will be required to follow. You must follow the law as given to you by the judge, without exception. Is there any reason you feel you could not follow the judge's instructions? _____________

58. Do you have any religious, philosophical, or moral beliefs that you will not permit you to sit in judgment of another person? ___No ___Yes

IF YES, please explain: _____________

59. What is your opinion of the American criminal justice system and why?

60. Is there any matter not covered by this questionnaire that should be brought to the attention of the attorneys and the court because it would affect your ability to be a fair and impartial juror? ___Yes ____No

IF YES, please explain: ____________