"Motion to Compel Defense Counsel To Wear Appropriate Shoes":

From Lowering the Bar, via Cory Doctorow (boingboing):

1. This is an action alleging personal injuries . . . .

2. Trial is set to begin on June 15, 2009.

3. It is well known in the legal community that Michael Robb, Esquire, wears shoes with holes in the soles when he is in trial.

4. Upon reasonable belief, Plaintiff believes that Mr. Robb wears these shoes as a ruse to impress the jury and make them believe that Mr. Robb is humble and simple without sophistication. . . .

* * *

6. Part of this strategy is to present Mr. Robb and his client as modest individuals who are so frugal that Mr. Robb has to wear shoes with holes in the soles. Mr. Robb is known to stand at sidebar with one foot crossed casually beside the other so that the holes in his shoes are readily apparent to the jury . . . .

7. Then, during argument and throughout the case Mr. Robb throws out statements like "I'm just a simple lawyer" with the obvious suggestion that Plaintiff's counsel and the Plaintiff are not as sincere and down to earth as Mr. Robb.

8. Mr. Robb should be required to wear shoes without holes in the soles at trial to avoid the unfair prejudice suggested by this conduct.

See also this Palm Beach Post article.

UPDATE: Thanks to commenter Ming etc. for the pointer to this followup story:

A lengthy auto negligence case ended in a mistrial this week after jurors saw and discussed a Sunday Palm Beach Post column about two lawyers in the case.

Jurors had heard nine days of testimony and were about to hear closing arguments Monday when a juror showed other panel members Frank Cerabino's column headlined "Does lawyer who bares sole have ace in the hole?" Palm Beach County Circuit Judge Donald Hafele had earlier instructed jurors not to read or consider any information about the case outside court and not to discuss the case at all before they began deliberations....

Hafele, however, did not tell the jurors of the mistrial and allowed them to deliberate and reach an "advisory verdict." In that verdict, which will not apply, jurors found Bone's client should receive the entire $2.2 million in damages he had sought....

The case will likely have to be tried again, [Bone] said, and that will again cost more than $50,000 in expenses....

Joseph Slater (mail):
So, basically a real-life variation on the old SNL "Unfrozen Caveman Lawyer" schtick?
7.10.2009 4:38pm
MCM (mail):
I half-expected this to involve John Lee Riches.
7.10.2009 4:41pm
Anderson (mail):
Hm. In Mississippi, an inappropriately-clad lawyer might risk drawing a contempt citation, or the threat thereof. Haven't seen any "hole-y" lawyers here.
7.10.2009 4:47pm
spot:
The next motion will be to stop attractive female lawyers from showing too much cleavage because of the unfair advantage this gives them. Clearly this is a path that we cannot go down.
7.10.2009 4:48pm
troll_dc2 (mail):
I seem to recall a decision in a Louisiana federal court in the early 1970s allowing a female lawyer to wear a pantsuit.
7.10.2009 4:53pm
Phil Smith (mail):
Wasn't it Darrow who would insert a wire into a cigar, and then light it as opposing counsel began their closing arguments? (The ash grows impossibly long, and was intended to distract the jury).

Or is that story apocryphal?
7.10.2009 4:59pm
Ming the Merciless Siamese Cat (mail):
It gets better:

Case ends in mistrial after jurors saw and discussed 'Palm Beach Post' column

http://tiny.cc/mV2BB
7.10.2009 5:01pm
MCM (mail):
troll_dc2:
I seem to recall a decision in a Louisiana federal court in the early 1970s allowing a female lawyer to wear a pantsuit.


must... have... citation...
7.10.2009 5:10pm
troll_dc2 (mail):

troll_dc2:
I seem to recall a decision in a Louisiana federal court in the early 1970s allowing a female lawyer to wear a pantsuit.


must... have... citation...



I don't remember the name of the case or the date, and it was before the Internet was revealed to the world. If you have access to Daily Labor Report indexes from that time, you might be able to find it.
7.10.2009 5:28pm
GD:
I'm reminded of Robert Duvall's big firm lawyer character in "A Civil Action" who carried a ratty, taped-together briefcase.
7.10.2009 5:32pm
Ben P:
This reminds me of a motion filed in our local state court by a relatively recent graduate that was entitled "motion to enjoin the defense counsel from touching or molesting the plaintiff's visual aids"

It was followed up by an email from the judge that was three words "are you serious?" and the response "Sorry, we've since talked and worked it out, the motion is withdrawn."

The motion and attached emails made the rounds around a local bar that a lot of lawyers frequent.
7.10.2009 5:39pm
Houston Lawyer:
A friend of mine worked for the federal prosecutor. After trials, one judge would ask jurors what they thought about the demeanor of the lawyers.

The jurors objected to my friend's dangling earrings. In addition, two karat engagement rings, which would not be a big deal at a law firm, really don't set well with jurors.

Even in the big city, big firm lawyers don their plastic watches and ill fitting suits.
7.10.2009 5:47pm
Owen H. (mail):

This reminds me of a motion filed in our local state court by a relatively recent graduate that was entitled "motion to enjoin the defense counsel from touching or molesting the plaintiff's visual aids"

It was followed up by an email from the judge that was three words "are you serious?" and the response "Sorry, we've since talked and worked it out, the motion is withdrawn."

The motion and attached emails made the rounds around a local bar that a lot of lawyers frequent.



I used to work as a courier, and a common job was transporting boxes of files to and from the courts. One morning, I arrived to deliver a couple of boxes and some other items to discover that although the lawyers that hired us hadn't arrived (and therefore couldn't sign for it), the other side had. Usually when the client isn't there yet, a court employee can sign, but since other side was there I was instructed specifically to wait and watch the delivery.
7.10.2009 5:55pm
zippypinhead:
LoL! Wasn't there a vaguely similar scene in My Cousin Vinny when the Judge, played by Herman Munster, er, I mean Fred Gwynne, took exception to Joe Pesci's courtroom attire?

But seriously - I knew a very senior litigation partner in a Biglaw firm who never took his $1000 custom briefcase to court. He always had his secretary rummage around for well-used redweld folders to carry his documents in. Never wore his hand-made suits or expensive Italian shoes for jury trials, either. And he demanded that the rest of the trial team from his firm go off-the-rack for trial, too. He once explained that looking decidedly middlebrow while representing large and wealthy corporate defendants was his "costume." His reputation for success was such that it apparently worked.

And then there's uber-litigator David Boies -- at least when I had dealings with him a number of years ago, he always wore sneakers to court. Black, fairly subdued sneakers, but sneakers nonetheless...
7.10.2009 5:55pm
alkali (mail):
FWIW, I think this is a perfectly appropriate motion in limine.
7.10.2009 6:07pm
whit:
there are two kinds of defense lawyers.

one that dresses appropriately and professionally.

but we are all familiar with the CLASSIC "rumpled defense attorney" look cultivated by such legends as kunstler. pj orourke has riffed on this, quoting from memory, but referencing lawyers getting their suits custom wrinkled at the pinko defense attorney dry cleaner.

i have also never seen a prosecutor with old school elbow patches on their suit jacket, but have seen defense attorneys wearing these.

there's also this one defense attorney (now a judge) who use to wear these RIDICULOUS high water pants.

don't the trial lawyers in england (barristers i think they are called) have to wear UNIFORMS, or is that only the judge?

there is some logic to requiring defense and prosecution to wear a uniform. i'm not saying i'm for it. and i don't mean a paramilitary uniform, like cops wear. i'm just referring to it in the classic sense - UNIFORM.
7.10.2009 6:11pm
neurodoc:
And then there's uber-litigator David Boies -- at least when I had dealings with him a number of years ago, he always wore sneakers to court. Black, fairly subdued sneakers, but sneakers nonetheless...
Not just sneakers. Boies is known as indifferent to fashion, indeed being something of an anti-fashionista. Reportedly, he buys multiples of the same nondescript off-the-rack cheap black suit and wears them at all times, not just when in front of a jury defending biggies like Greenberg in the AIG/SICO trial.
7.10.2009 7:18pm
neurodoc:
What is with some jurors, they don't think the judge is serious when he tells them they are not to read the papers or listen to the news until the trial is over? And then they discuss with fellow jurors what they have seen/heard/read about the case?! Do judges ever give such individuals a day in the clink or other suitable punishment for failing to follow orders?
7.10.2009 7:21pm
ShelbyC:

Hafele, however, did not tell the jurors of the mistrial and allowed them to deliberate and reach an "advisory verdict." In that verdict, which will not apply, jurors found Bone's client should receive the entire $2.2 million in damages he had sought....


That's pretty crappy. I wonder if there's a due process violation there? A judge can order jurors to come server jury duty, but I don't think the can order them to come deliberate for his amusement, can he?
7.10.2009 7:23pm
Careless:
don't the trial lawyers in england (barristers i think they are called) have to wear UNIFORMS, or is that only the judge?


Yes, whit, although I believe there is a degree of flexibility (you can choose who makes your outfit but it must match specs). Those wigs are stupidly expensive.
7.10.2009 8:07pm
Steve:
A judge can order jurors to come server jury duty, but I don't think the can order them to come deliberate for his amusement, can he?

It's not "for his amusement." An advisory jury is specifically provided for under the Federal Rules, and quite possibly under Florida law as well. If the jurors all get to go home early as a result of causing a mistrial through their own conduct, that certainly puts the incentives in the wrong place, among other things.
7.10.2009 8:12pm
Careless:
this is a link (I hope) to a store selling the various things a English Lawyers/judges need to wear (what I found when I was curious about this a few months back). Different styles for the various regions of GB, too.
7.10.2009 8:12pm
ArthurKirkland:
About 20 years ago, a federal judge threatened to jail a female lawyer for (a) using "Ms." rather than "Mrs." and (b) using her maiden name rather than her married name.

The judge also imposed a 30-day sentence of imprisonment for contempt (later stayed) on the female lawyer's co-counsel, who had attempted to defend her.

If I recall correctly, in the same district at roughly the same time, another judge originally refused to permit a female lawyer to wear a pantsuit in court, then relented and indicated he would permit her to wear pants in the courtroom . . . if she produced her husband's written consent.

A far different time, indeed. Or, as some might say (perhaps after ensuring no troublemaker is within earshot), "those were the days."
7.10.2009 8:25pm
zippypinhead:
About 20 years ago, a federal judge threatened to jail a female lawyer for (a) using "Ms." rather than "Mrs." and (b) using her maiden name rather than her married name.

The judge also imposed a 30-day sentence of imprisonment for contempt (later stayed) on the female lawyer's co-counsel, who had attempted to defend her.
Although I couldn't find it in the usual 90-second short-attention-span Google search, I remember reading about that incident at the time. Even back in the dark ages of the 1980s, I seem to recall that the rather elderly Judge was basically shamed into publicly apologizing, and before long retired.

I'd say "time have changed" since then, except that I think the times changed quite a few years earlier - but the Judge apparently didn't get the memo.
7.10.2009 8:59pm
ArthurKirkland:
The judge was Hubert Teitelbaum of the Western District of Pennsylvania. I am certain he was the judge who threatened to jail the woman for using her maiden name -- 'you will do as I say, or you can explain to your husband why you are sleeping at the county jail instead of with him' is a reasonable paraphrase of his contribution to American justice that day -- but I am not sure he is the one who threatened to jail a woman for wearing a pantsuit in court. I am relatively confident the pantsuit episode occurred after the maiden name episode, so the 'times changed quite a few years earlier' memo apparently took some time to complete circulation. Indeed, I sense we still have plenty of bigots, sexists, racists, homophobes, xenophobes, and the like inhabiting our midst.
7.10.2009 10:35pm
Bill Poser (mail) (www):
I refuse to wear most dress shoes because most of them have soles with poor traction. I now realize that it may not have been an accident that it was my lawyer brother who alerted me to the existence of a brand of shoes with hiking-boot like soles that look more-or-less like dress shoes.
7.10.2009 10:54pm
Tony Tutins (mail):
My favorite casual shoes now have holes in the soles, and I noticed Clarks no longer makes them, so I can sympathize.

Michael Robb may have taken a leaf from Adlai Stevenson's notebook. I remember seeing a picture of a hole-in-shoe sole-shaped notepad. Stevenson was trying to make the point that he was dedicated to finding out what the people wanted, using much shoeleather in the process.
7.10.2009 11:30pm
Dan Simon (mail) (www):
I wonder what would have happened if the defense lawyer had worn those Michael Jackson-patented shoes?
7.11.2009 1:17am
Michael Alexander:

I used to work as a courier, and a common job was transporting boxes of files to and from the courts. One morning, I arrived to deliver a couple of boxes and some other items to discover that although the lawyers that hired us hadn't arrived (and therefore couldn't sign for it), the other side had. Usually when the client isn't there yet, a court employee can sign, but since other side was there I was instructed specifically to wait and watch the delivery.

I don't get it.
7.11.2009 1:26am
anonfun:
I love the update about the mistrial. Bones got exactly what he deserved for filing such an asinine motion.
7.11.2009 9:47am
Tony Tutins (mail):

I don't get it.

The theme is opposing counsel molesting one's exhibits.

The poster was making a delivery to a courtroom. The attorneys expecting the delivery weren't there. Courier had to remain with his delivery in presence of opposing counsel lest something bad happen to it. Had they not been there, courier could have simply left it with court personnel.
7.11.2009 12:14pm
ChrisTS (mail):
The author of 'Netherland' was interviewed on NPR this week and talked about his days as a barrister in the UK. He said they never get new wigs, just keep the old ones as they become rattier and rattier. He also said they have an odd smell (even the new ones).

On the other hand, he said he thought it was good practice to have a kind of uniform precisely to keep distractions of appearance to a minimum. But, if the older barristers have ratty looking wigs, aren't they at a disadvantage?
7.11.2009 1:29pm
neurodoc:
But, if the older barristers have ratty looking wigs, aren't they at a disadvantage?
You think they hang on to the old ones because they're too cheap to shell out for new ones? (Anyone know how much a decent barrister's wig costs?) Perhaps it is a form of reverse chic, an old ratty looking one bespeaking years in practice, with the implication of experience, wisdom, greater credibility, etc. Have you never heard of wealthy people (most often ageing white males) who wear shirts with frayed collars, jackets with patched sleeves, worn shoes, etc., and it is seen as a reflection of the fact that they can afford to be indifferent to the the impression they make by their clothes?
7.11.2009 2:05pm
Cornellian (mail):
I wonder how he'd react to seeing me walk into court in flip-flops.
7.11.2009 2:46pm
Fedya (www):
neurodoc:

According to Careless' link above, a barrister's horsehair bar wig costs £525.

On the other hand, I can buy a wig that makes me look like a white Don King for only $23.98 -- less if I shop around.
7.11.2009 2:48pm
neurodoc:
neurodoc: According to Careless' link above, a barrister's horsehair bar wig costs £525.
Wow, according to their website, Ede &Ravenscroft has been in business since 1689! (I expect their website is of more recent vintage.)
7.11.2009 4:18pm
Brian G (mail) (www):
Letting the jury deliberate in an advisory manner is very valuable. Here's why, They heard 9 days of evidence and rendered their "verdict." This guarantees the case will never be tried again because it will settle. You can bank on it. I have worked as both a defense and Plaintiff attorney and if I were a defense attorney I would recommend to my client to try and settle because it is very likely another jury will reach a similar conclusion.

Anyone who has done insurance defense has written those valuations where you guess how a jury might come down, using verdicts in similar cases, your experience, etc. The advisory jury removes the guesswork.
7.11.2009 9:11pm
Larry Fafarman (mail) (www):
I remember seeing a picture of notorious serial-killer Ted Bundy wearing a suit and tie at his trial. A prison jumpsuit would have been more appropriate.
7.12.2009 1:19pm
Mr. X (www):
I remember seeing a picture of notorious serial-killer Ted Bundy wearing a suit and tie at his trial. A prison jumpsuit would have been more appropriate.



I'm pretty sure it would have been unfairly prejudicial.
7.13.2009 12:32pm
David W. Hess (mail):
I was recently on a jury for a 2 day civil trial where only one other juror and I noticed that the plaintiff's attorney had a hole in the sole of his shoe and that his paper folders were held together by duct tape. I apparently was the only one who attached any significance to the demeanor of the witnesses. The plaintiff for instance, while being the best dressed, seemed to suffer from some kind of malady presenting as attention deficit disorder combined with a language problem.

If anything we observed was a ruse, I can hardly cast the first stone. I delayed getting my hair cut short for summer in a failed bid to get dismissed from service. Fainting in the jury assembly room was apparently effective for one person though.
7.14.2009 1:13am

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