1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

PROPHET PAULCIN,

Plaintiff,

vs.

DUANE SPEARS, et al.,

Defendants.

CASE NO.: 4:10-cv-483-RH/WCS

PROPOSED VOIR DIRE QUESTIONS

NOTICE IS HEREBY given that PLAINTIFF, by and through its undersigned 

counsel and pursuant to Fed. R. Civ. P. 47 and this Court’s Order (D oc. 74), hereby 

files its Proposed Voir Dire Questions, as follows, to wit:

1. Are you or your spouse affiliated with law enforcement? Any relative or close 

friend affiliated with law enforcement?

2. Are you or your spouse related to a law enforcement officer? Any relative or

close friend related to a law enforcement officer?

3. Have you or your spouse ever received any formal training in law enforcement?

4. Do you have any relative or close friend who has had any training in law 

enforcement?

5. Have you or your spouse ever received any formal legal training? Do you 

have any relative or close friend who has had any legal training?

6. Does any member of the prospective jury panel have any prior jury

experience? Was there anything in your prior jury experience that upset you to 

the extent that jury service was an unsatisfactory experience?

7. Is anyone currently involved in a lawsuit as a plaintiff or defendant?

8. Have you or any member of your family ever been employed by an 

attorney?

9. Have you or your spouse ever been a member of a grand jury?

10. Have you or any member of your family ever been enlisted in any branch of the 

armed forces of the United States of America?

Case 4:10-cv-00483-RH-WCS Document 64 Filed 10/10/11 Page 1 of 4
2

11. Have any of you, a member of your family, or a close friend ever been the 

victim of a crime? Would this experience cause you to favor the Defendant in 

this case? Do you feel that you would in any way have difficulty rendering a 

fair and impartial verdict in this case?

12. Have you a member of your family or friend ever been accused in any 

criminal action?

13. Have you a member of your family or friend ever suffered from mental 

illness?

14. Has anyone you know ever been incarcerated who was suffering from a 

mental illness?

15. Do you believe that people who are incarcerated are entitled to the same 

standards of medical treatment as those who are not?

16. Do you believe that people who are incarcerated have lost their right to 

decent care or treatment?

17. Have you or a member of family ever made a claim under any state or federal 

civil rights laws? If so, what kind of claim was it and who was it against? What 

was the end result?

18. Have you or any member of your family or any friend ever been a witness in any 

kind of case?

19. Have you, your spouse or any member of your family or friend ever been 

connected with the judicial system?

20. Have you, your spouse or any member of your family or friend ever been 

connected with the State Attorney's Office?

21. Have you, your spouse or any member of your family or friend ever been 

connected with the Florida Attorney General’s Office?

22. Is anyone familiar with any of the witnesses in the case?

23. Has anyone ever been involved in a lawsuit involving plaintiff’s counsel?

24. Have you or any member of your family, or a friend, ever been associated 

with, or worked with, any program that was dedicated to the rehabilitation of 

persons convicted of a crime?

25. Do you know, or have you known, anyone who has been to prison? 

26. What are your feelings in general about the criminal justice system? 

27. What are your feelings in general about the state prison system? 

Case 4:10-cv-00483-RH-WCS Document 64 Filed 10/10/11 Page 2 of 4
3

28. Have you known anyone who has had a serious problem as a result of drug use?

29. Have you known anyone who has had a serious problem as a result of mental 

illness?

30. Have any of you known other prospective jurors on this panel before coming to 

Court?

31. Have any of you heard, or do you have any knowledge of the facts or events in 

this case?

32. Have any of you, or a family member or friend, been in a situation where there 

was the need for assistance from someone in law enforcement? How would 

you describe that experience?

33. Do you have any adverse or pro feelings towards law enforcement in 

general? Would any pre-existing feeling toward law enforcement cause you to 

favor any party in this case? Do you feel that you would in any way have 

difficulty rendering a fair and impartial verdict in this case?

34. Do you have any adverse or pro feelings the Florida Department of 

Corrections? Would any pre-existing feeling toward law enforcement cause 

you to favor any party in this case? Do you feel that you would in any way 

have difficulty rendering a fair and impartial verdict in this case?

35. Have you or any member of your family been involved in a lawsuit of any kind 

against either an individual or a corporation, partnership or against any 

governmental entity? What kind of suit? What was your experience like? Were 

you a plaintiff or a defendant? How did you feel about the court system when it 

was over? Did you learn anything in the case that you might use in making 

decisions in this case?

36. Can each of you sit here and withhold judgment or the formulation of an 

opinion until the Plaintiff has had an opportunity to present its witnesses and 

evidence?

37. Do you think a law enforcement officer would less likely than another person to

lie under oath?

38. Do you believe that mental anguish, humiliation, embarrassment and other types 

of damages cannot be compensated in money damages? 

39. Do you believe there should be fixed limitations on money damages?

40. Do you believe there are too many lawsuits?

41. Do you believe that you shouldn’t find money damages against a public entity 

because your taxes may go up?

42. Do any of you have any religious affiliation or beliefs that would prevent you 

Case 4:10-cv-00483-RH-WCS Document 64 Filed 10/10/11 Page 3 of 4
4

from serving as a juror and rendering a verdict?

43. Do all of you understand that you may use your experience in every day 

affairs in evaluating the truthfulness of witnesses and the weight of the 

evidence which you will hear in the trial?

44. Is there any reason which we have not covered in voir dire which would 

affect your ability to be fair and impartial to both sides?

45. Are there any questions that any of you can think of that I might have forgotten to 

ask which might be relevant to whether you can be a fair and impartial juror?

Case 4:10-cv-00483-RH-WCS Document 64 Filed 10/10/11 Page 4 of 4