The Latest Craze - "The Reptile Theory" - Trial Strategy for the Plaintiff and How to Defend Against It




9:00-10:15 a.m.


The Reptile strategy has by analyzed, developed, crafted and perfected by the plaintiffs’ bar as an effective means of breaching the prohibition of breaking “The Golden Rule”.  The plaintiff’s bar has always wanted to approach the jury and say, “Put yourself in my client’s shoes”.  They want the jury to decide a case based on emotion and passion as a means of maximizing the damages awarded by the jury. 
But, that pesky “Golden Rule” and Tennessee Pattern Jury Instruction 1.01 -Before Voir Dire, puts a full body block on that effort by mandating that the plaintiff’s lawyer can’t do it, subject to objection and admonishment, if not a mistrial and confronting jurors at the beginning of trial that “Jurors must be as free as humanly possible from bias, prejudice, or sympathy and must not be influenced by preconceived ideas about the facts or the law.”
So, what can the plaintiff’s lawyer do to avoid the limitations of The Golden Rule and T.P.I. 1.01?  Ladies and Gentlemen, I give you  . . . . The Reptile Theory.
The Reptile Theory is based on the foundation that you can prevail at trial by speaking to, and scaring, the primitive part of jurors’ brains.  It is that part of the brain humans share with reptiles.  O.K.  . . . stop laughing!  This is serious and there is clear evidence that when properly prepared and executed, it works!

The Reptile Theory strategy purports to provide a blueprint to succeeding at trial by applying advanced neuroscientific techniques to pretrial discovery and trial.  So as with any offensive (plaintiff) or defensive (defendant) litigation angle, the success or defeat of the Theory begins in Discovery.
The fundamental concept is that the reptile brain is conditioned to favor safety and survival.  I was attending a Trial Tactics seminar a couple of years ago and was in conservation with some other attorneys.  One of the attorneys shared the following: 
“Plaintiffs' lawyers have changed. They're all talking about "safety" now, and that word is finding its way into every deposition: "What is the safe procedure?" or "What would've kept Mrs. Johnson safe?" They're all talking about safety and security instead of standard of care.”

By framing arguments in terms of our most biologically basic need for security, the theory goes, plaintiffs are able to successfully tap into jurors' primitive or "reptile" mind.  And when the Reptile decides, our conscious mind and reason-giving ability follows.  Based on that unifying concept, the perspective has taken the plaintiff's bar by storm, spinning off more books as well as frequent trainings.  "Cases are not won by logic," they write, "you need to get the Reptile to tell the logical part of the juror’s brain to act on your behalf. To get the Reptile to do that, you have to offer safety."
Therefore, if plaintiff’s’ counsel can reach the reptilian portion of the jurors’ brains, they can influence their decisions and the jurors will instinctively choose to protect themselves, their families, their community, their town, their County and their State from danger through their verdict.  The Verdict is their way of confronting the threat to their safety and survival created by the acts of the defendant regardless if the defendant is an individual or a business entity. 
Get your arms and head around this . . . the Verdict has nothing to do with the plaintiff in the case.  It has everything to do with convincing the jury to collectively place themselves in the shoes of the plaintiff and confront the danger and threat that the defendant’s conduct and actions create to the jury.  The verdict is a by-product of the success of doing so.
Thus, the focus of the plaintiff’s case is on the conduct of the defendant, not the injuries of the plaintiff.  Now, I want you to think back at your trials as a plaintiff’s lawyer, defense lawyer or both and examine how the plaintiff’s side of the case was tried.  It was all about that plaintiff.  Not about how the defendant’s conduct or actions created a threat to the safety of others, their families, their community, their town and their state.
The use of this trial tactic results in jurors not necessarily being interested in plaintiff’s injury, even when severe, according to the theory.   Rather, the only truly effective way to engage jurors is to demonstrate how the defendant’s conduct endangers the jurors and their families.  Wait. Before you start to worry about malpractice, let’s look at how its done and how to defend against it.
The gurus of Reptilian trial strategy are David Ball and Don Keenan, whose book, “Reptile: The 2009 Manual of the Plaintiff’s Revolution” purportedly gives a significant edge over the defense in jury trials.  Several prominent lawyers on the plaintiff’s side have cited this book as the new bible of advocacy.  Plaintiff lawyer Pat Trudell advocating the theory in an article titled "Beyond the Reptilian Brain" and has gone as far and to proclaim, "The Reptile Always Wins".
But do they?
The defense bar mounted a counter-attack.  Minton Mayer of Wiseman Ashworth Law Group in Tennessee (DRI, The Voice, 9/25/13), provides some effective tips for defusing the subliminal codes plaintiffs seek to embed in the jury’s psyche.
In his article titled, “Make Boots Out of That Lizard – Defense Strategies to Beat the Reptile,” Mayer provides good tips for defusing the subliminal codes plaintiffs seek to embed in the jury’s psyche.
In the April 2013 edition of For the Defense, David C. Marshall, a lawyer with Turner Padget Graham & Laney PA in Columbia, South Carolina, provides an in-depth discussion of new trial strategy in "Lizards and Snakes in the Courtroom."  According to Marshall, using the "reptile" successfully "requires creating safety rules and demonstrating that a defendant violated the rules, subjecting a plaintiff and the surrounding community to needless danger….  Thus, in closing, the lawyer using this strategy must show a jury how the dangers presented by a defendant extend beyond the facts of a case and affect the surrounding community so the entire case boils down to community safety versus danger."  Marshall provides useful litigation tips for keeping the reptile at bay during trial.
Similarly, Kathy Cochran, a defense lawyer with Wilson Smith Cochran Dickerson in Seattle, WA, cautioned in  the DRI Blog Today in 2010, "As defense lawyers, we need to recognize this [Reptile strategy]  for what it is. It is an attempt to resurrect Golden Rule arguments, which are usually impermissible. Jurors are not to be asked to put themselves in the place of a party and make a judgment based on that virtual reality. Ball and Keene provide advice to their readers on how to circumvent this evidentiary rule. "  
Cochran cautions, "we will now see plaintiffs emphasizing ‘safety rules’ and trying to gain admissions from defense experts that such rules are important for the safety of the community. "Never separate a rule from the danger it was designed to prevent. … The greater the danger, the more the Reptile [juror] cares." 
In an article titled, “Atticus Finch Would Not Approve: Why a Courtroom Full of Reptiles is a Bad Idea,” (American Society of Trial Consultants, May 2010), authors Stephanie West Allen, Jeffrey M. Schwartz and Diane Wyzga provide a scathing critique of reptile theory and suggest that an effective alternative is providing jurors with a persuasive narrative at trial. According to the authors, reptile strategy “disrespects” jurors and could result in juror backlash. Fear-based tactics direct attention in an uncertain and unpredictable manner; in contrast, thoughtful narrative directs attention toward action grounded in the reflective mind. According to the authors, “narrative shines the mental flashlight of attention which can refigure the brain and change behavior.”
How does The Reptile Theory work? The goal, through witness examination and closing argument, is to capitalize on jurors’ innate need to minimize survival dangers.  In other words, the evidence and argument must convince a juror, not only that the defendant acted negligently, but also that, such conduct threatens the juror’s community (beyond the single plaintiff), which could include the juror and his/her family.
Next, the Opening Statement and Closing Argument must be crafted so that the jurors are made to feel empowered, by virtue of their verdict, to prevent this conduct, thereby protecting the community.  The goal in getting jurors to think (conceivably with the reptilian part of their brains) that they should return a winning verdict even when logic or emotion might cause jurors to find against the plaintiff on an issue; and (2) to maximize the size of the verdict, by encouraging jurors to think beyond the risk or the harm suffered by the individual plaintiff, to their own safety and the safety of the broader community.
Lawyers can invoke or establish broad “safety rules” which the defendant violated, and which would have avoided the harm if they had been followed.   Each “Safety Rule” has to possess the following in order to trigger jurors’ sense of self- preservation and, thus, their reptilian brains:
1.       The rule must prevent danger;
2.      The rule must protect people in a wide variety of situations, not just the plaintiff;
3.      The rule must be in clear English;
4.      The rule must explicitly state what a person must or must not do;
5.      The rule must be practical and easy for someone in the defendant’s position to have followed; and
6.      The rule must be one that the defendant will either agree with or run the risk of looking stupid, careless or worse yet, dishonest. 

Keenan and Ball begin with the broadest possible “Umbrella Rule:” 
“Do you agree that a [_______] is not allowed to needlessly endanger the public?”  (Fill in the blank: driver, doctor, car maker, construction scaffolding supplier, etc.)

“Do you agree that when a [_______] does [_______], they are needlessly endangering the public?”

The next step for the plaintiff’s lawyer is to Draw Admissions, from the defendant, the defendant’s witnesses and/or its experts, to gradually narrower, more case-specific, safety rules.
Let’s take a doctor.  Under the umbrella rule that “A doctor is not allowed to needlessly endanger the public,” for example, the case-specific rule is, “[I]f a cardiologist has a choice between two treatment alternatives, he/she is negligent unless he/she elects the absolute safest choice.” After all, if a doctor picks any alternative that is not the absolute safest, he/she is needlessly endangering the public, right?
The rule must prevent danger and the rule must protect people in a wide variety of situations, not just the plaintiff.  The rule must be in clear English; the rule must explicitly state what a person must or must not do.  The rule must be practical and easy for someone in the defendant’s position to have followed and the rule must be one that the defendant will either agree with or run the risk of looking stupid, careless or worse yet, dishonest. 
Let’s take a context of a motor vehicle accident involving a driver of a passenger car (plaintiff) and a tractor-trailer (defendant).  The plaintiff’s lawyer should attempt to employ the following techniques during the defendant driver’s deposition:
1.       Establish general safety rules – i.e. truck drivers should be well rested prior to commencing their driving duties or non-driving duties, such as carrying out pre-trip inspections with as much precision and care for safety as driving
2.      Get every defense witness to agree to the safety rules
3.      Establish that violating these safety rules can hurt anyone (by inference, members of the jury and their family)
4.      Get the witness to agree that the plaintiff was acting like everyone else – doing normal and routine activities of daily living
5.      Emphasize safety first, last, and always
6.      Repeat principles, such as “No prudent person needlessly endangers anyone” and “Violating a safety rule is never prudent”
7.      Establish the defendant did not care about safety from the start
8.      Establish the defendant did not care about the person he hurt and does not care now
9.      Establish the subject occurrence taught the defendant nothing
10.   Establish the defendant did not have the knowledge to do the job safely; unlike a mistake, a lack of knowledge is a preventable danger
11.    Build on trying to make the defendant the least safety-knowledgeable person in the courtroom
12.   Expose the defendant as a liar – inconsistencies, gaps in documentation, evidence preservation, prior bad acts – anything that hurts believability and likeability
13.   Show that the defendant did not do his job
(See BALL & KEENAN, at 209-24).
For defendants looking at the prospect of the other side increasing their effectiveness by appealing to the survival instincts of the reptile brain, here is what I'd suggest:   
Step One: Strip Away the Brain Baggage
A central support for the Reptile approach is the "Triune Brain" theory is the notion that there are three discrete parts to the brain reflecting the stages of evolution:

Reptilian complex at the core of the brain (primitive and survival-based), Paleomammalian complex located in the mid-brain (focused on emotion, reproduction, and parenting), Neomammalian complex at the top (capable of language, logic, and planning).
But it is that basic reptile level, the theory goes, that drives our behavior, and even when we think we are acting based on the language and the logic of our neomammalian brains (e.g., in deliberation), we are unknowingly responding to the commands of the reptilian brain.   Proponents of the The Reptile Theory claim that the Reptile invented and built the rest of the brain and now she runs it.   The message being conveyed by their belief is that since the Reptile is in control of our thinking, our persuasion needs to tap into the only things that waken and motivate the Reptile: safety, security, a freedom from threats. That is what makes the approach unique and powerful at a level that goes beyond reason-giving and is essentially precognitive.
Attorney Mark Bennett wrote in a blog post entitled "Lizards Don't Laugh," that civil defendants can confront the attempt by plaintiff lawyers to use The Reptile Theory by doing the following:
a)     make a stronger appeal to the reptile brain, or
b)     disengage the reptile brain, and engage the dog brain or the ape brain."
He goes on to suggest that communicating The Golden Rule by either requesting that the Court instruct the jurors and the plaintiff’s attorney or by explaining it to jury in Voir Dire and Opening Statement gets the jury out of their reptile minds.
He also suggests creating incongruity and relief, gets the jury out of their reptile minds.  He suggests full frontal confrontation with the “Use of the Tactic” by explaining it to the jury will show them that this is a typical plaintiff’s lawyer trick and to fight against being taken advantage of in order to put the plaintiff’s lawyer in a bad light as simply a wolf in sheep’s clothing.  “That lawyer is using this tactic claiming to be a crusader against threats to safety and the danger created by my client, but is really simply trying to elicit emotion from you for money.”
Step Two: Recognize that What is Left is Different, But Still Valuable

Los Angeles plaintiffs' attorney Sonia Perez Chaisson put it succinctly in The Jury Expert“We care not at all about brain anatomy and solely about whether the Reptile works.”  And by all indications, it works.
But it most likely works not because its users have found a way to communicate directly the fact finders' primitive reptile brains, but simply because attorneys are recognizing that motivation exists and picking a very strong motivation angle to speak to. Instead of applying the rational-legal model of jurors reasoning their way to a conclusion by applying the law to the facts and deducing to a verdict, the Reptile practice forces attorneys to speak to what would make jurors care about the verdict. The principle of motivated reasoning is that once jurors, or any other decision makers, know what decision they want to reach, and then they'll have no problem coming up with reasons to support that conclusion. The decision comes first and the reasons are filled in later.
So, what is the defense angle and how can you motivate a jury with that angle.  Speak to the motivator. Make it an individual motivator, and make it an important motivator.
Step Three: Find Your Own Motivation
A central part of Ball and Keenan's argument is that the Reptile approach is a tool that helps one side, not the other. “The Reptile prefers us," meaning plaintiffs, "for two reasons: First, the Reptile is about community (and thus her own) safety – which, in trial, is our exclusive domain. The defense almost never has a way to help community safety. The defense mantra is virtually always, ‘Give danger a pass.’ Second, the courtroom is a safety arena," they write, "so when we pursue safety, we are doing what the courtroom was invented and maintained for." Defendants might quibble that the more limited purpose of the court is to resolve the claim before it, and not to broadly enhance society's safety with each verdict. But at the level of personal injury, product, and medical malpractice suits, Ball and Keenan do have a point in emphasizing that it is often easier for the plaintiff to invoke safety than the defendant, except in those cases where the defendant's own conduct is the more salient source of the danger.
But remember, although “Safety” and “Security” may be a very powerful human motivators, they are far from the only human motivators.
Smart defendants will tie their own case to a powerful principle that Responsibility, Innovation, or Fairness is at stake.
It can even be a strong appeal to empower jurors to resist the pull of an emotive safety-based verdict, and instead base their decision on evidence, science, and facts.   There is one source of insecurity that plaintiff lawyers have that can be hung on a plaintiff's case by an effective defendant’s lawyer.  The idea of a common citizen juror being manipulated by a plaintiff’s lawyer can be very threatening, if not devastating to the plaintiff’s case.
Call out the Reptile strategy by name, pin it as a tactic and preview to the jurors what the plaintiff lawyer as done in Voir Dire and is likely to do in the Opening Statement and/or Closing Argument. Just like any other strategy, it becomes less effective when it is known and named. 
Defend Against the Umbrella Approach and the Use of “Safety Rules”

            As stated above, lawyers invoke or establish broad “safety rules” which the defendant violated, and which would have avoided the harm if they had been followed.   Each “Safety Rule” has to possess the following in order to trigger jurors’ sense of self- preservation and, thus, their reptilian brains:
1.       The rule must prevent danger;
2.      The rule must protect people in a wide variety of situations, not just the plaintiff;
3.      The rule must be in clear English;
4.      The rule must explicitly state what a person must or must not do;
5.      The rule must be practical and easy for someone in the defendant’s position to have followed; and
6.      The rule must be one that the defendant will either agree with or run the risk of looking stupid, careless or worse yet, dishonest. 
1. Protect Your ‘Safety Rules’
The key to the plaintiff’s ability to persuade a jury is to ground the case, not in a legal standard of care, but in a “safety rule,” or a commonsense principle juror can immediately understand and apply to other contexts.  Once the lawyer is able to identify such a rule, and show fact finders the danger to themselves and the community when it’s violated, then they’ve awakened those jurors’ reptile brains, motivating them to equate justice in this case with their own security.
Underlying all six elements of a safety rule is a black and white view of the world. But the advantage for defendants is that the real world isn’t black and white, but is instead situational and highly dependent on a case set of particular circumstances. This sets up a conflict that has existed prior to and aside from this Reptile approach, but has been magnified by it: As plaintiffs’ attorneys push for a black and white worldview, defendants push back with a realistic appraisal of shades of gray.
The response on each of the six elements of the Umbrella Rule for Use of Safety Rules must be used to prepare fact and expert witnesses for depositions and trial, conduct voir dire, and create openings and closings. Each effort to deny a safety rule in your own case can be part of your message at trial.
2.  The Safety Rule Must Prevent Danger
Of course, nothing is able to literally and fully “prevent” danger. Teach your jury that the reality is that real life is often swapping one danger for another based on the facts of the case.  Or, better yet that they like the defendant are simply ordinary, reasonable, prudent people who who have acted the same way under the same or similar circumstances.
In the context of a medical malpractice action nothing is able to literally and fully “prevent” danger. Teach your jury that physicians are instead trying to lessen its impact or control its course. The reality is that medical care often involves swapping one danger for another in an imperfect effort to make the patient better off. For example, you prescribe a drug with known side effects in order to treat a condition that is, probably, worse than the side effects. This means that the line from the Hippocratic Oath to “first, do no harm” isn’t literally true. Excising tissue in a surgery, for example, is doing harm, but a lesser harm than doing nothing. This, of course, is something that doctors, claims representatives, and defense attorneys understand intuitively. Jurors may resist the message, wanting to believe that physicians can guarantee safety. With a little explanation, however, they can realistically set that notion aside.
3. The Safety Rule Must Protect People in a Wide Variety of Situations,
Not Just Someone in the Plaintiff’s Position

Key to the Reptile’s advice is to encourage jurors to abstract beyond the particular plaintiff and to view the rule as broadly applicable and personally relevant.  Always be case specific.  Reduce the issue to the case at hand.  Always draw the jury back to what happened on this day, this moment, this accident, this plaintiff and this defendant. 
4. The Safety Rule Must Be in Clear English
A dumbed-down principle can be a less accurate principle. Complexity for its own sake is the defendant’s enemy, and can be rightly seen as obfuscation. But realistic complexity — factors and distinctions that are critical to the situation in your case that can be patiently and accurately taught to the jury — is the defendant’s friend.
5.  The Safety Rule Must Explicitly State What a Person Must or Must Not Do
The key language here is “must” and “must not.” There is no room in a Reptile perspective for “typically,” “probably,” or “in most cases.” It has to be an imperative: “If the doctor sees X, she must do Y.”  There are plenty of situations where it isn’t a “must” or a “must not”.  It fact, more often than not, it is a realistic “it depends.”   Help jurors understand that by explaining and supporting all of the factors that go into what happened.
6.  The Safety Rule Must Be Practical and Easy for
Someone in the Defendant’s Position to Have Followed

Things are often practical and easy in hindsight.  But, your case involves the circumstance of what was known or believed at the time.
In the context of a medical malpractice case an example would be , could the physician have ordered a different test at an earlier time? Of course, that is going to be both practical and easy. But did the physician have solid reasons at the time to have ordered that test? That is a different question.
Of course, getting jurors past this psychological preference for hindsight can be a challenging task, but not an insurmountable one. You can encourage jurors to adapt a hindsight-resistant mindset by using a timeline to walk through the story based on what was known at the time, not just the one obvious choice that could have been made in hindsight.
7.  The Safety Rule Must Be One That the Defendant Will Either Agree With or Reveal Him or Herself as Stupid, Careless, or Dishonest in Disagreement

This final rule really sums up the mindset: You either agree with a simplistic rule, or you are stupid, careless or dishonest. To fight back, you need to mount an educational offensive that frames the choice as something other than that. For example, craft your own safety rule that is simple, yet honest: a principle that jurors can understand and that the defendant followed in this case. If the true rule is a little more complicated than the plaintiff’s proffered rule, then make jurors proud of the extra effort it takes for them to get it: They aren’t taking the easy route; they’re taking the accurate route.
A lot of time, the safety questions are in the form of hypothetical safety questions and are more specific and often take the form of an if-then statement, like “Doctor, you would agree that if you see A, B, and C symptoms, then the standard of care requires you to order tests X and Y, correct?”  Then there is the nightmare at trial:
Attorney: “Doctor, patient safety is your top priority, isn’t it?”

Doctor: “Yes, of course.”

Attorney: “And the emergency procedure you chose to perform during Mr. Smith’s surgery wasn’t very safe because it resulted in his death correct?”

Doctor: “That’s true, but you have to understand that I-”

Attorney: (with emphasis) “Doctor you didn’t make Mr. Smith’s safety your top priority, and because you are ignoring your own rule, you put Mr. Smith and perhaps all of your patients in danger, didn’t you?”

It is at this point the Reptile Plaintiff attorney has his or her claws into the witness. Jurors simplify the case to be one in which the doctor knowingly put his patient at risk and violated his own safety rule.
These questions are effective because they provide just enough information (compared to the big picture safety questions) to lure defendant witnesses into providing an inflexible, absolute answer. By definition, the safety rule and hypothetical safety questions are inherently flawed because they lack the proper specificity to allow for a specific answer.
Therefore, the only honest answer to a vague, general question is a vague, general answer.  For instance, a response to the question posed above would be “It depends on the circumstances”, “Not necessarily in every situation”, “Not always”, “Sometimes that is true, but not all the time” and “It can be in certain situations”
The bottom line that the defense attorney must training a witness to withstand these reptilian attacks and that goes far beyond traditional “witness preparation.” Instead, more sophisticated witness training is needed, as the witness must undergo cognitive and communicative restructuring.  Witnesses must literally develop a new process of thinking and communicating through intense conditioning methods to ensure cognitive and communicative changes take place.