Welcome to The Legal Truth, the podcast created to provide you general legal information about South Carolina law lawyers and the legal process, and hopefully prevent you from being surprised by the unexpected. We will answer many of the questions I've been asked during the past 35 years about South Carolina personal injury claims and workers' compensation claims. We'll also discuss existing laws and propose changes in the law and how they affect you. My name is Dirk Derrick. I'm the founder of the Derrick Law Firm, and I'm your host.
Please see required ethics disclaimers in show notes.
Welcome to the Legal Truth Podcast. Today we're talking about the truth about focus groups and the leverage they give our clients. And I'm here with Pearl Carey, the co-host. Welcome Pearl. Thank you. Another podcast.
I'm so excited to be here and to speak about focus groups.
Yeah. Anyone who knows me, who've been around me for the last two years have heard about focus groups because it is a subject matter that excites me. I believe it's the best thing we have done for our clients in the 35 years I've been practicing law. So I love to talk about it. I love to answer questions about it and explain to people what's so good for our clients.
Absolutely. Well, thank you again for having me here. And first questions first, what is a focus group and how do we conduct them? At Derrick Law Firm,
A focus group is a group of people that don't know anything about a case who we bring into our office and we present a case to 'em from both perspectives, the plaintiff's perspective and the defense perspective. And we give them all the admissible evidence. We don't tell 'em if we're involved in the case or whether it's our case or another attorney's case. We don't tell 'em who we're representing. We present the case to them and let them give us their feedback on the facts and the issues, the damages, the parties. We just get a lot of feedback from
'em. So what I'm hearing you say is that it kind of functions as if it were a real trial, but it just kind of occurs at one of our offices or across the state of South Carolina. Correct,
Correct. Okay. If you think about it from our standpoint, in 35 years, no one I represent want to file a suit and sue somebody.
Right
On the other side, no one wants to be sued, but the mechanism to determine if someone has a valid claim and the value of that claim is a jury. And historically it's taken two to three years to get in front of that jury.
It's a long time.
It's a long time. It's expensive, it's not fun going through litigation
Process. Yeah,
I believe there's a lot of unnecessary litigation, but with our system it becomes necessary because there's always a disagreement in every case from the insurance company standpoint and from our standpoint as to what 12 people will think about these particular parties, these facts, these issues, these damages, what
They'll
Say. That's the dispute. So we now do these focus groups early on as soon as we can gather most of the admissible evidence that a jury would hear to get their feedback earlier. So the purpose from our standpoint is to speed up the process, get to the point where, get to the point where 12 people are telling us what they think about the case. We do it. So we do it before we file a lawsuit on cases that we can get the evidence without filing a lawsuit. So it allows us to see what 12 people think about it and then show it to our client, show it to our attorneys, show it to the insurance company, and try to prevent unnecessary litigation.
And with respect to the 12 people that are participating in this jury, where are you getting these 12 people from? Are they from people in the community or?
Yes. Okay. They're people from the county in which the case is pending. Got it. Or would be pending if you file the lawsuit. We want to get the community standard when it comes to what's acceptable behavior and what's unacceptable behavior, and then what they think about these kinds of facts, what they think about these issues, what they think about these damages. And in one case, we can learn more than anyone knows about that one particular case. We know more about our case than the insurance company, the defense lawyer, or anybody we're going against because we have shown it to people who have no dog in the fight who have given us their honest opinion. If we do that two or three times during that case, we know greatly more than anyone else.
Right.
Absolutely. Way more.
And so how often are these focus groups occurring?
We started at the end of 19, had to take a six month break because of Covid and since the end of 19 to now, I passed the 400 jury mark this week.
Wow, that's amazing. So
I have watched 400 juries deliberate the facts and issues that we face in all of our cases.
So having walked out those 400 or some juries at this point, what are some main takeaways that you've had or that other attorneys have had going through this experience?
There are a lot.
I
Bet there are a lot. I think the overall thing we've learned is for 30 years we didn't know what we were talking about when we were trying to give advice to our clients as to what the value of a case is.
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If you don't have this information and your client says, what's the value of my case? The only thing you have to base that value on is what you may have gotten in court when you tried one case, two cases a year for the last five years with different people and different issues or what other attorneys have gotten in court and you don't know how they prepared the case and the specifics of those cases, or I think what most people base it on is what insurance companies want to pay. Well, what insurance companies want to pay and the real value of the case are two different things. Insurance companies are in the business to make money. They're to make money for their shareholders. That's their job. I don't hate what their job is. They have always had leverage on my clients in three different ways. They've had the leverage of money to where they have unlimited funds to fight you.
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They have the leverage of time. The longer they can drag out a client, the less money that client will take because they get tired of it, right? It's a long process. Insurance companies holding their money, making interest on investments, your client's going through bad times and they're dragging it out. That's in the best interest of their shareholders. So you can't hate 'em for doing it, but that's what they're doing. And they've also always had the leverage of uncertainty to where they can say, we'll pay you this amount today, we don't think it's worth anymore. If you think it's worth more, go litigate a case and in a year and a half or two years, see what a jury says, but they may not give you as much. So they have those three leverages. The purpose of establishing these focus group, the purposes are to flip those leverages as far as flipping the leverage of money.
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We've gotten to a point now in a size now that we can compete with any, I mean, they can't outspend us. If they want to spend money, we'll spend money with them. So that doesn't affect us anymore. It affected me when I was a solo attorney and having to meet payroll. They had the leverage of money on me. They don't have the leverage of money on me anymore. The other two leverages the leverages of time. If we take the jury process and we move it up two years, we have now come up with a way to see what 12 people think about the case way faster. And so we have taken away that well see what they say two years from now. Now we'll see what they say next Wednesday night. So we've taken away that leverage and then the leverage of uncertainty. You've taken away some of the uncertainty with the focus groups too, because when our client can look and say, well, those 12 people think that they agree with me, I feel more confident about going forward.
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Whole jury agrees with me. Yeah. Second time we focus group, they agree with me too. I feel more confident about going forward. In the same way, if the first jury says you don't have a case, if they say that, we try to determine is there any way to fix it? Are there any facts that would change your mind? And often they'll say, yes, you show me A, B, and C, I'll change my mind. So you go get A, B, and C and then you focus it again. But some jurors will say, no, this fact right here is a killer. And we can show that to our client. I mean, we're trying to determine what the real value is,
Give them a realistic expectation
And they'd much rather have it now than when they find out two years when we walk out of a courtroom that their case had no
Value. And that could be heartbreaking at all.
It can be heartbreaking.
So after doing so many focus groups, how would you say you used what you've learned in these cases now with the rest of your new cases?
Well, the one leverage we've always had is that under South Carolina law on every insurance policy other than workers' comp, there is an implied covenant of good faith, which means the insurance company is supposed to make reasonable decisions in order to protect their client. If it's a third party insurance policy, a liability policy, and if it's my insurance policy that I've paid a premium on, they're supposed to act in good faith and base their decisions of claims on a reasonable basis. So we've had that leverage of you need to act in good faith. If you don't act in good faith, you can be sued for bad faith insurance practices. They don't want to be sued. Our focus groups have allowed us to leverage the truth by showing them what these juries think about the case and what it does. It gives us leverage. We take away their leverage of time, we take away their leverage of uncertainty, and we play our card, our leverage of good faith for 30 years. I say, we think the case is worth 2 million. They say, we think the case is worth $300,000
And then it's just a disagreement. At that point,
We all adding in bad faith, no, we're not adding in bad faith.
This is what we think. This
Is what we think because of A, B, and C. Now they say, that's not what we think because of A, B, and C. I said, okay, go focus the case present A, B and C to 12 people. And if they agree with the insurance company, then you need to take it into consideration. But if they say, no, this case is worth more than $2 million A, B, and C doesn't matter to us, and you show that to an insurance company, now they act in a reasonable manner by not assessing the truth of what these people are saying about their defenses.
Because if they weren't taking that into consideration, perhaps that would be bad faith
If they do not listen to it. Okay. If they do not listen to what 12 people say after the case is fairly and accurately given to those people and we videotape the presentation, they see what we tell these people, they see, we make their arguments, they see, we use their evidence. So it's a lot different for them to watch and listen to 12 people in two different jury rooms dog their defenses than for me to tell them No, 12 people won't think that. Right.
Because an objectivity
As an objectivity. And that has given us the ability to leverage the truth that we've never had before. And it applies pressure because again, they're looking out for their shareholders. Their shareholders do not want them to be sue for bad faith.
Of course not.
So they're trying to pay as little as possible, but they surely don't want to be sued for bad faith and have a multimillion dollar bad faith against 'em because they didn't pay what was fair after we showed 'em what was fair.
Okay. And so when you're presenting the amount that maybe a jury has assessed in a focus group setting to these insurance companies, are you able to give them a specific exact number or is it more of an average, would you say?
It's both.
Okay.
When we present a case to a focus group, after the presentation, each person gives their anonymous opinion about the division of liability and damages, and then we divide into two juries and they deliberate and come up with a group number. Same thing would happen over at the courthouse. You come in and you start compromising. You got people here and here, they got a compromise. And then afterwards we ask them, okay, after hearing everybody itself, afterwards we ask them, after hearing everyone else's opinions, what would your verdict be if you were a jury of one?
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So we get it's just you. We get just them before they talk to anybody. We get the group and then we get, okay, do you agree with what you just compromised to or what would you do if you were in the room by yourself? So we are gathering that data from each one of them. And sometimes you'll have a real strong leader in a room that will strongly affect the other five, but we already know what the other five would do if they were on their own. Now leadership is something we grade, but it allows you to see an average of what they do, see if that presentation's made, what their attitudes going to be going into the jury room, and then you determine who leaders and followers are. And you also see what type of person, from a demographic standpoint, from a life experience standpoint, from a belief standpoint, what type of person is a good juror for this particular kind of case or maybe a bad juror for this particular kind of
Case. Good meaning ruling in favor of the plaintiff or Well,
In my opinion, that's a good juror if I'm, yes, that's a pro plaintiff or pro defense is what we're looking at. So we're getting data from the case and what these people think about the case, but we're also getting data about particular jurors and how their beliefs walking into a courtroom affects how they look at cases.
And is there any specific difference between an actual kind of trial situation versus a focus group? Are there any key differences or if a participant shows up to a focus group, can they kind of expect the same experience, if that makes sense?
They can expect a much quicker experience than the trial experience. If anyone's set on a jury at trial, they will ask you Why do we hurry up to wait? It can be a slow process. It's over days. There's breaks, there's arguments outside of their presence. It's a different thing. We are taking a lot of evidence and putting in about an hour and a half or two hour presentation before they divide up and reach decisions. So it's expedited. Okay,
That's good for the participants, I'm sure. Yes,
We will give them some uncontested facts and uncontested issues in a summary fashion and then we really pick up on he goes where the rubs going to be. He goes, what the plaintiff's position on this issue is and what the defense position on the damages. He goes, evidence of this from the defense side. He goes, evidence supports their position. It's really the value of it comes from doing it right. I mean, if the purpose was just to go and try to get big numbers, we could do that by just not showing a defense's position or if you wanted to go get a defense verdict every time you could do that. But that's
What is fair.
It has no value to our client. It has no value to our attorneys, our firm or anything. Right. It's got to be done fairly for leverage to occur. If it's not done fairly, they can always say, wow, that wasn't done. You didn't make my arguments, so it's got to be done. Right.
Absolutely. And so I know previously you mentioned that focus groups can occur sometimes two to three times even for the same case. What would the purpose of that kind of be? Would that be for the benefit of the client or just kind of to clean up some verbiage or how does that work?
We'll do it. There's some cases where you get most evidence without litigation. Okay. Kind of like a car wreck. If you have a car wreck officer investigation, you get pictures, you get pictures of the car. A lot of times you can get most of the evidence. Now we have found that in focus groups, they will punish someone who's distracted by their telephone while they're driving. So we do not have the legal ability to make them give us their phone records, but we'll ask the at-fault party to give us your phone records if you want to try to get this thing subtle without litigation, we need to have that because that's a fact that could add value or determine value of the case. If they don't give us that phone record, we may have to file suit just to go get the phone record to evaluate it.
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But the pre-lit stuff is usually there's amount of insurance coverage. We think we've already got enough facts to get all the money, but the insurance company's not offering us all the money. So we'll do a pre-lit focus group to see if these 12 people think it's worth more than all the money we did one of those last night we had an offer. We think the case is worth all the money. We focus group, both the groups came back substantially higher than the policy limits. And we'll use that to show the insurance company they need to go ahead and pay us the policy limits. Got it. That's good for our clients because we can get them all the money without litigation
And quicker
And quicker. They want the real value, they want it faster and they want to know that we're working for 'em. That's the three things. And so we did that. Some cases you can't get it before if it's a trucking case. And the question is, was this person properly hired? Had this person been driving too many hours in a row? Was he trained? Was he monitored? Was he pulling a load that was too heavy? There's all kinds of issues in trucking cases that they're not going to give you. Right. So if you have substantial damages, we know there's going to be substantial insurance coverage. We'll go ahead and file the suit
So you can get all that information then.
Yeah, once you file a suit, you have the ability to do discovery. You have ability to make them give you things and to subpoena things from third parties. We'll gather all that information. We'll go through the discovery process, but there's a mandatory settlement conference 300 days after you file a lawsuit. So we try to get all that stuff in and appraise it with a focus group before we go into mediation so we can show our client. And the other side here goes what the jury thinks about all these facts we have discovered over the last six to nine months.
So you can do a focus group during pre-lit and then during litigation as well.
Yep. You do one, we do it pre-mediation. You get all the facts and do it. And there's times when we do a focus group and the focus group says if we had A, B and C, we'd see this thing differently. We'd go out and take depositions to get A, B, C, and then refocus it to see if it does make a difference. But we do one before mediation. Again, you apply leverage if they believe that the case has value A and they're offering you down here, you use it to try to leverage them to pay you the fair amount and add in good faith. Got it. And then if it doesn't settle at mediation, we'll do one about a month out from trial and we'll do that on all day Saturday and we'll have openings and closings and present more evidence. And that one, we're really trying to fine tune the presentation
Before the case trial.
Before the trial trial. So if we get on a court roster, we usually have focused the case two or three times and there's one trial expert that says if you give a case to six group, I mean four groups of six people, you get 95% of the conversations in the real jury room. If we know what people are going to be asking in the jury room, we can prepare for that better if we have to try the case.
Got it. So what you're saying is each of these different focus groups, if there are two or three for the same case, can kind of be gathering information for different parts of the process before a case might go to trial? That's right.
Got it. That's right. Okay.
And what would you say is kind of the future for focus groups? I know you mentioned you've done 400 over the past few years, which is crazy. So what would you say is kind of up and coming for focus
Groups? I think the future is I will not be working in the morning anymore.
Night shift.
Night shift. I'm second shift had three second shifts this week, Tuesday, Wednesday, we had one last night in Conway. Tonight we got one in Conway and we got one tomorrow night in North Charleston, which you don't have to be helping with.
Absolutely be there all
Night. We now have courtrooms in Myrtle Beach, Conway North Charleston just bought our office on Main Street in Greenville and are starting the construction of the courtroom there. We're taking this focus group research statewide. We're already doing it for, we've been hired by our attorney out of Columbia, out of Greenville, out of Charleston, did a murder case for a local defense lawyer, been hired by some municipalities. So people are seeing it. People come and they see the value of it. So we're doing it. We're expanding it, trying to find out the difference in the different counties. There's counties, insurance companies, rate counties. Wow. And pro plaintiff, pro defense or moderate, and they base it on what verdicts are in those counties. And I don't know if they rank it also on what lawyers and counties will take for their cases if they'll take less than other counties, but they have rankings. Right now we've got people signed up in every county in the state, so we don't take it statewide so that we also have cases on almost every county in the state. So if we get hired in whatever county, we want to be able to provide the same service.
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It is so valuable. I mean, just in the last month we've had cases that have offered 200,000. We focused at got a million dollars, and in 15 days after you've
Really changed the game.
Just when we can show that and leverage that, it just gives our clients a lot of leverage
And it can definitely shorten the process. That's probably already long and really difficult.
Absolutely. You think about what we do, we represent people going through some bad times and some bad financial times. If they're not working or they've got hospital bills and all this stuff.
Stressful.
It's stressful and litigation is stressful. So anything we can do to speed that up but still give 'em the real value. I mean, there's ways to turn and burn cases. There's ways to take 30 cents on the dollar and get people quick
Money, finish it up,
And there's ways to get 'em the real value, but it takes 3, 4, 5 years. Both of those have negatives
Of course.
Either you get it fast and not get real value or you get the real value. You have to wait years and we've tried with this process and what we do is to take the best of both worlds. Let's get it faster, but let's get the real value and let's not take the value that the insurance company wants to pay.
Let's get the real value.
Let's get the real value. And that definition of the real value for us, the definition is what would a jury in that county give us at trial if we picked the best jury we could based on the data we know about those jurors and these types of cases, and we present the case in such a way that we present every fact. They want to hear based on what focus groups have told us in the fashion that has worked with focus groups, proven presentation models, what is that verdict? That's the real value. We have focus groups that tell us what the value is. You get one focus group say it is this value that's a data point. You can't guarantee we're going to go get that from a jury. You get two juries, still two data points, but now you got 24 individual data points. You go three juries, you got 36 opinions.
Right. And a history of similar cases that also have been focus grouped as well.
That's the true leverage that we're building by doing this focus group.
Absolutely.
Our clients today, when we focus group their case, don't just get the value of what the jury says about their focus group
At one point in time,
At one point in time, but we may have 60 other juries who've decided the same issue
In the same county.
In the same county. So when you show an insurance company, hey, he goes the real value. And not only is this what this focus group is saying, but he goes, 60 of the cases we have focused regarding a drunk driver and what people think the punitive damage award should be. If they're going to act in good faith, they have a hard time ignoring that.
Right. Saying no. Yeah, absolutely.
So the purpose of the entire thing, the entire focus group process is to get our clients the real value faster. My purpose in doing it, I'm getting old, but before I drop off this earth, I want the database of information that prevents people from being drug out by the insurance industry. I want the ace of spades. I want the ultimate leverage to show them. Here goes what the community standard is in Horry County. Here goes what the community standard is in Greenville County. Do not make people file unnecessary litigation. If you do, you're subjecting yourself to bad faith cases.
Absolutely. So I know that you referenced some data points previously when speaking about jurors. Tell me a little bit more about how those data points work and the importance of having more than one.
Yeah, there's two things we're learning. When we focus cases, we're learning about the case, how this county thinks about cases like this. Overall, we don't pick a jury or the best jury for our focus group. Anybody serves in a focus group. We got insurance agents, adjusters, we had an insurance defense lawyer. Oh wow. I've had three or four lawyers serve. There's some people who do focus groups say, you need to take those people off because they wouldn't really be on juries. I like 'em on it. I like people from every walk. I like the worst possible jurors that we would never even think about putting on a jury because when they start making arguments, it requires the other people to stand up and speak their truth or what they believe the truth is. So it is a good exercise for our lawyers to learn how to present cases and to empower good jurors to stand up against those people. Right.
Or how to present to everybody. That's
Right. Because in the jury room, there's going to be people in almost every case on both ends of the totem pole, and then there's going to be people in the middle. And we're trying to, during the presentation models, learn how to best empower the good jurors to stand. If somebody's making an argument that's outside the facts of the case, to be able to say, Hey, that's outside the box. We're not supposed to consider that. But the best way to do that is to let people serve who you wouldn't otherwise put on the jury. And we also getting the information about the case, but we're getting the information about the jurors, just jury research. I mean, there's a reason they fill out a hundred questions about their demographics, life experiences, and their beliefs before they ever meet us and come into our courtroom. We are determining who are good jurors for this particular type of case and who are bad jurors for this particular type of case.
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We're breaking it down to where were we determining who are the good jurors on the liability question, who's at fault? Who's the bad jurors on the liability question? Who's the good and bad jurors on the punitive damage award? The award where you punish reckless conduct? Who makes a good juror in that case? Who makes a bad juror in that case, who makes a good juror on this issue and that issue? And the more we learn from that and the more focus groups we do and the more data we collect, you then start playing the legal version of Moneyball. You ever seen that movie even Moneyball? Yes. Have you play odds? Right? You play odds. You say, we've done 200 cases, we've got 2,500 data points on how people in this county feel about this issue. Let's gray 'em out. Well, women grayed out here, men grayed out here, Republicans grayed out here, Democrats grayed out here. You start breaking it down and then you also look at the question, the answers they gave you to the survey and say, what's the difference? What makes a good juror for this case and a bad juror? Is it their beliefs? Is that where it separates? Is it demographics? Is that where it separates or is it life experiences?
So you're picking up on trends throughout these focus
Groups. We're picking up on trends. We're studying the data and we'll end up having some predictive analytics to help us pick juries. And that's where we're headed.
And that's all contingent on the county. And all those demographics
Is contingent on a lot of moving parts. What we do have that I've never seen before, and what excites me about it is we were very guilty during my first 30 years of prize of picking juries based on demographics.
Okay,
This type of person or that type is dangerous. This type will be good for you. And I can tell you after 400 juries, that's hogwash. That is so dangerous and we were so wrong. Really, you cannot do it. It is amazing what we have determined about picking juries based on demographics. Amazing. Can't do it. You got to go deeper. You got to go down to their beliefs, their life experiences. We all bring a history with us into the courtroom,
A wealth of experiences,
And we all have lived separate lives. We all have different biases. Biases used bad most of the time, but everybody's got biases. Absolutely. I mean, it is just the way we look at the world and those make a difference in how people determine cases. And we are in the process of knowing who makes good for particular types of cases. And there's some fine lines. There is a demographic who can be a very good juror and can be a very bad juror, and they look very similar. I mean, it's the same demographic and we haven't totally figured that out yet. I think it has to do with people who are happy with their lives and people who aren't
Really. Yep. So it can come down to different beliefs and things like that.
You can take the same demographic, same political beliefs,
Same county even.
Yeah, same county. But we're diving into learning how to pick the best juro. That's why I said the real value is based on what the best jury we could pick in this county or the best juror we can pick in this county is going to be based upon the data we're collecting as we're talking. And
I'm sure throughout 400 jury research focus groups, you've gotten quite a bit of that information.
Yeah. I mean, I think we've had between six and 7,000 people sign up. Wow. So we got that many surveys and we're getting those people as fast as we can. We're doing three or four a night, we're building courtrooms. We're going to use those people as fast as we can to give them opportunity to serve about, I think 95 or 98% of 'em want to do it a second time.
Absolutely.
They really enjoy it. I mean, people enjoy, people love it. The law. They love having an influence,
Being a part of something,
Having their voice heard. So it's a good process. It's good for our clients to tell 'em about the case, but it's also good for our clients to help us pick juries if we go to court.
Absolutely. And is there anything else that you'd like to add about jury research focus groups and the impact that it has on the community overall?
Well, I do believe it's something that have an impact on the community because as we get this data, not only is it helping our clients, not only is it helping our attorneys to expedite cases, but it's also establishing community standards. And as those community standards get established and the insurance industry know how this community feels about these issues, if my family member is injured next year, they can benefit from all this data we're getting. So in the long run, my hope is that all the work we're doing on this will not only get our clients to grow value faster, but will also our entire community value faster without unnecessary litigation when litigation is not needed to
Us, to everyone's benefit,
I think it will be to everyone's benefit. That's my, that's my goal. And I think I absolutely believe that it will be beneficial for everyone who has an insurance claim in the future involving the issues that we are working with.
Definitely. Well, thank you so much for speaking to me a bit about jury research focus groups, and the impact it can have on attorneys, clients in the community overall. I'm Pearl Carey and I hope that our listeners took a lot away from this podcast and we look forward to seeing you on the next one.
Thank you.
Thank you for joining us on The Legal Truth Podcast. If you have questions that you would like answered on a future episode, please send them to the [email protected]. If you would like to speak to us directly, call us at (843)-248-7486. If you find the podcast valuable, please leave us a five star review and share the legal truth with your neighbor, friend, or family member who is seeking reliable information about a South Carolina personal injury or workers' compensation claim. Dirk J. Derrick of the Derrick Law Firm Injury Lawyers is responsible for the production of this podcast located at 901 North Main Street, Conway, South Carolina. Derrick Law Firm Injury Lawyers has included the information on this podcast as a service to the general public. Use of this podcast in any related materials, does not in any manner constitute an attorney-client relationship between Derrick Law Firm Injury Lawyers, and the user.
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While the information on this podcast is about legal issues, it is not intended as legal advice and should not be used as a substitute for competent legal advice from a licensed professional attorney. In your particular state, anyone seeking specific legal advice or assistance should retain an attorney. Any prior results mentioned, do not guarantee a similar outcome. The content reflects the personal views and opinions of the participants in the podcast and are not intended as endorsements of any views or products. This podcast could contain inaccuracies. The information contained in this podcast does not constitute legal advice and is not guaranteed to be correct, complete, or up to date as laws continue to change.