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On November 26, 2012, Catholic priest Christopher Wenthe appealed his 2011 conviction for sexual misconduct. (1) On appeal, the Minnesota Court of Appeals found that the evidence against Father Wenthe was excessively intertwined with religious matters, and suggested that the jurors were prone to base their judgments on religious standards rather than the state's legal standards. (2) The court further found that the jury was unable to render an impartial verdict due to their own religious beliefs and their beliefs about Wenthe's religion. (3) Thus, Wenthe was granted a new trial. (4) The court's decision suggests that when juries are guided by religious standards to judge a defendant, they are guided in a biased manner. (5)

One issue that arises is whether or not jurors knowingly act on their religious beliefs when deciding a verdict for a defendant. It is quite easy to assume that religious beliefs can influence jurors' decisions and likely do so without the jurors being explicitly aware. However, evidence that jurors acknowledge their religious beliefs during the decision-making process is not as clear. During the trial of Corrine Brown, a juror was removed during the deliberations and the jury was forced to restart because the juror told the judge, when asked if a higher power told him that Corrine Brown was not guilty, "No. I said the Holy Spirit told me that." (6) In this example, the juror clearly understands and acknowledges the influence of his personal religious beliefs on his decision about the guilt of the defendant. Yet, it is still unresolved whether or not religious beliefs actually influence jurors' decisions. The purpose of this review is to summarize the information put forth by both the legal and academic communities examining this topic and to also assess the extent to which religious beliefs might bias jurors' decisions and how such biases arise.

Attorneys and judges know that potential biases exist in jurors (7) and often times they attempt to address these biases in the voir dire process, a process in which judges or attorneys can exclude jurors from the juror pool based on potential impartiality for or against the defendant. (8) However, this typically requires that judges and attorneys ask the right questions in order to identify targeted biases. (9) Prospective jurors have been removed during the voir dire process (10) for religious reasons such as church membership or having a religious occupation. (11)

For example, Catholics were excluded from the jury in the Boston Marathon bombing trial due to their religious beliefs that the death penalty should not be imposed if non-lethal options are sufficient enough to protect the public from the aggressor. (12) Judges and attorneys might ask jurors directly about their religious beliefs; other times they will include religious questions on questionnaires that they give to members of the jury pool. (13) In both approaches, the goal is to identify juror bias related to religion. However, it is also challenged, as in Young v. Davis, that attorneys' removals of jurors for religious reasons are a pretext to other types of discrimination (e.g., race or gender). (14)

Though some attorneys use gut instincts, intuitions, and anecdotal observations to drive voir dire decisions, (15) it is critical to examine empirical support for assumptions regarding the relationships between religious beliefs, affiliation, and orientation and juror attitudes and decisions. In this review, Part I reviews research attempting to establish an association between religious affiliation and biased decisions. Part II reviews research attempting to establish a relationship between jurors' specific religious beliefs and biased decisions. Part III reviews research attempting to establish a relationship between jurors' specific religious orientations and biased decisions. Part IV examines ways in which a defendant's religion relates to jurors' decisions. Parts V and VI address the current knowledge and review implications for researchers and practitioners.


Much research investigates relationships between religious affiliations, attitudes toward legal issues, and punitiveness toward criminals. (16) Religious affiliation is usually defined as the overarching set of religious beliefs and rituals in which people categorize themselves. (17) This would include Catholicism, Judaism, and Protestantism, as well as denominations or traditions within religions, such as Orthodox Judaism, Roman Catholicism, and Lutheranism. (18)

Attorney Clarence Darrow once suggested that prosecuting attorneys should seek Baptists, Lutherans, and Presbyterians for jurors because they are more likely to render convictions in criminal cases. (19) Although Darrow's suggestions are not empirically based, they offer insight into the relationship between jurors' religion and their decision-making. A former prosecutor, John Quatman, openly admitted that he regularly excluded Jews from serving as jurors because of their unwillingness to give the death penalty. (20) Religious affiliations have gained attention from both attorneys and researchers because many affiliations contain teachings that may guide individuals' decision-making. (21) Darrow's and Quatman's claims about religious individuals were not supported by any concrete evidence beyond observation and personal experience, but they represent lay theories used to guide challenges during voir dire. (22) Thus, it is critical that social scientific research related to such claims be examined in order to determine its congruency with attorneys' assumptions.

In general, the Catholic and Presbyterian Churches oppose the death penalty, but Southern Baptists and the Lutheran Church support it. (23) According to these identified positions on the death penalty alone, Darrow's claims would be 66.66% accurate. (24) Darrow and Quatman make blanket statements and leave no room for variation within denominations and traditions. Particularly, differences between races regarding civil issues occur within religious denominations. (25) For example, white mainline Protestants and Catholics share similar favorable attitudes toward gay marriage, but white evangelical Protestants starkly oppose it; moreover, black Protestants and Hispanic Catholics differ in respect to their attitudes toward gay marriage and abortion. (26) To make assumptions on affiliation alone is to err. Other factors play significant roles in shaping attitudes, and ultimately decisions, among jurors.

One issue that has received quite a bit of attention is whether or not Batson v. Kentucky (27) extends to religious groups and the question of whether or not this should be the case. (28) To date, the U.S. Supreme Court has not ruled clearly on this issue, and religious groups are not currently a protected class like race (29) and gender. (30) In one example from California, People v. Martin, a defendant appealed a prosecuting attorney's use of a peremptory challenge based solely on the fact that the venireperson was a Jehovah's Witness and, thus, unable to judge others. (31) The California Court of Appeal held that this does not violate the Equal Protection Clause because the challenge is based not on race or gender but on religious beliefs, which have noticeable influence on an individual's perception of right and wrong in many criminal and civil cases. (32)

This ruling was important for two reasons. First, it reiterated the findings in Batson and J.E.B that religion was not equivalent to race and gender as a cognizable group. (33) Second, it legitimized the idea that religious beliefs likely influence jurors' decisions (as in are related to specific biases), and in seemingly obvious ways. (34) The peremptory strike used in People v. Martin was further supported in the first trial of Kevon Neal when a juror, who had already been questioned in voir dire and was retained for the jury, recused herself because her religious convictions as a Jehovah's Witness were too strong to be impartial. (35) Thus, not only do judges claim that jurors' religion can influence their decisions, but jurors, themselves, confirm this.

A. Affiliation and Attitudes Related to the Death Penalty and Criminal Cases

Religious affiliation has been of particular interest in death penalty cases. Death sentencing trials require a death qualification process in which potential jurors are excluded if their attitudes for or against the death penalty would interfere with their duties to be impartial. (36) In the Boston Marathon bombing case, venirepersons were removed because of their Catholic beliefs, (37) yet it is unknown if this was specific to the case or if this is a systematic exclusionary trend. In the death qualification process, Jews, atheists, and agnostics were disqualified more often, but Catholics and Protestants were retained more often, (38) which is quite interesting considering the contrast in death penalty support among Catholics and Protestants. (39) However, more recent research suggests that Catholics were more likely to be excluded during the death qualification process. (40) This discrepancy might be the result of the Catholic Church's shift in attitudes toward the death penalty--from support to opposition. (41) Nonetheless, venire persons' religious affiliations continue to be reasons for exclusion. (42) Moreover, different death qualification standards (43) used across jurisdictions might also impact who is and who is not excluded; (44) and this likely extends to religious-based challenges.

When asked about the death penalty, Christian affiliations, compared to non-Christian affiliations, were more supportive of the death penalty--although no differences were found within traditions among Christian affiliates. (45) Also, according to research, being Protestant (46) or Christian fundamentalist (47) was positively related to death penalty support. Death penalty support varied among Protestant groups, such that Evangelical and fundamentalist Protestant affiliates were more supportive of the adult death penalty than were Liberal affiliates. Among white participants, Catholics were less supportive of the death penalty than non-Catholics (48) and less supportive of the juvenile death penalty (49) than evangelical and fundamentalist Protestants. (50) In one study, 79% of Southern Baptists, compared to 53% of non-Southern Baptists, voted for the death penalty on their initial votes. (51)

Although much of the research regarding religious affiliation and denomination differences in attitudes and decisions focuses on death penalty cases, jurors' religious affiliation also influences verdicts in non-death penalty cases. For instance, in a child molestation case, Jews were less likely than Christians to vote for conviction. (52) Because death penalty cases receive substantially more research attention than non-death penalty cases, more research is needed to better understand the role of religious affiliation in jurors' attitudes and decisions regarding the death penalty and particularly non-death penalty crimes.

B. Affiliation and Attitudes toward Civil Issues

Religious affiliation is also associated with differences in attitudes toward civil issues. For instance, Protestants were more likely to believe in an overabundance of frivolous lawsuits, compared to Catholics and individuals with no particular affiliation. (53) Also, evangelical Protestantism was negatively related to support for the legal right of same-sex marriage. (54) However, current research is severely limited. This might be the result of criminal cases involving more morally polarizing issues such as rape, murder, and theft, which are crimes that are addressed in the Bible and often associated with the Christian commandments. In contrast, civil issues, such as organizational wrongdoing, copyright infringement, patent disputes, and privacy disputes are not directly addressed in the Bible. These civil issues might elicit less extreme reactions and responses, and thus, not evoke jurors' religious beliefs during decision-making. More research regarding civil trials is needed to better understand these differences.


Although it is important to study the relationships between religious affiliations and attitudes or behaviors toward certain criminal and civil issues, (55) it is also important to address differences among specific religious beliefs, particularly fundamentalism, devotionalism, evangelism, evangelicalism, and Biblical literalism. It is unlikely that all individuals within a single tradition, or affiliation, hold identical beliefs (e.g., afterlife, God and Satan, etc.).

A. Fundamentalism

Religious fundamentalism, sometimes referred to as conservativism or religious orthodoxy, is characterized by belief in a single divine true God, Biblical truth, a sinful human nature, and that individuals are accountable for their actions because they have free will. (56) Fundamentalism is measured differently throughout the literature, (57) but it has consistently predicted punitiveness. (58) Fundamentalism was positively associated with death penalty support, (59) punitive verdicts in an insanity case, (60) and harshness and length of criminal sentences. (61)

Also, fundamentalists were more likely to vote for the death penalty over life in prison, (62) and low scores of fundamentalism were related to more punitive responses toward vigilantism, (63) suggesting that fundamentalists approve of the actions of those who punish wrongdoers. Fundamentalism was also associated with more negative attitudes toward the insanity defense (64) and support for punitive responses toward parents who use faith healing for their children over traditional medicine. (65) Overall, this literature is consistent with earlier findings suggesting that individuals who affiliate with Christian Fundamentalist churches are more supportive of the death penalty and generally more punitive. (66) These relationships might be explained by the fundamentalist belief that people are personally responsible for their actions and should be punished accordingly; (67) however, more research is needed in order to determine this.

B. Devotionalism

One aspect of religion that might be influential in individuals' lives is their devotion to their religion. Devotionalism is characterized by frequency of religious participation, commitment to religious ideals, religious importance (e.g., religious salience), and identity in religious beliefs. (68) Devotionalism was positively related to assigning a more severe sentence (69) and the belief in the death penalty as a deterrent. (70) In contrast, devotionalism was negatively related to death penalty support, (71) but this differed depending on the age of the defendant, such that devotionalism was related to less support for the death penalty for young offenders compared to older offenders. (72) Devotionalism was also positively associated with more punitive responses toward vigilantism. (73) Punishing vigilantes might imply general punitiveness toward any wrongdoer or it might suggest leniency or sympathy toward the vigilante's victim(s). Also, it is possible that vigilantism is associated with revenge and heightened emotional states (e.g., anger, hate, rage, etc.), and it might be assumed that vigilante punishment is more violent than punishment by law. In this case, individuals might simply oppose vigilantes' use of violence.

Although the relationship between devotionalism and juror attitudes might seem mixed, the difference might be in the way devotionalism is defined in different studies (e.g., religious service attendance, time spent in religious activities, or importance of religion). (74) Another possible explanation of mixed results is the sample itself. Currently, there is little understanding of how devotionalism might relate to jurors' attitudes and decisions differently within affiliations and denominations. For example, a highly devout Jewish sample might have different attitudes than a highly devout Southern Baptist sample. Thus, it might be more beneficial to examine devotionalism in the context of affiliations and other religious beliefs.

C. Evangelism and Evangelicalism

Evangelism is the aspiration to evangelize and proselytize others. (75) Evangelism was negatively related to support for the death penalty, (76) especially for those who were devoted to practicing their religion, (77) and punitiveness toward vigilantism. (78) Evangelicalism is characterized by the importance of evangelism and proselytizing paired with the strict belief in salvation through Christ (e.g., being born again as a religious believer). (79) Although evangelism and evangelicalism appear similar, they differ in that evangelicalism requires strict beliefs in salvation through Christ. Thus, evangelicalism likely pertains specifically to Protestant Christian believers whereas evangelism is not as narrowly defined. Among Catholics and Protestants, evangelicalism was related to more punitive attitudes toward criminals; however, the effect among Catholics washed out when accounting for beliefs that the world is a just and fair place and that people get what they deserve. (80) Lastly, beliefs about personally being born again were related to support for the adult death penalty. (81) Overall, evangelicalism was related to more punitive attitudes. Thus, evangelism and evangelicalism conflict in their influence on punitiveness. Because evangelism and evangelicalism differ in their emphasis of salvation, it is possible that this difference is responsible for the opposing relationships with punitiveness.

D. Biblical Literalism

Biblical literalism is the belief that the Bible is not subject to individual interpretation (82) and how literally one interprets the Bible is related to legal attitudes. (83) For example, the "eye for an eye" passage would imply justification for jurors to give a murderer the death penalty. (84) Biblical literalism was positively related to death penalty support (85), punitiveness toward juveniles, and support for stricter laws and prison terms for juvenile offenders. (86) Also, Biblical literalists had a higher likelihood of favoring the death penalty over life in prison when compared to non-literalists. (87) Overall, Biblical literalism was related to greater punitiveness.


Research has demonstrated the relationship between religious affiliation, religious beliefs, and legal attitudes and juror decisions; however, juror attitudes and decisions might also be related to religious orientation. Religious orientation can be described as religious motivation or the reason a person engages in religion. (88) There are three main dimensions of religious orientation: quest orientation, (89) intrinsic orientation, and extrinsic orientation. (90) Each dimension of religious orientation characterizes a unique approach to religion and religious beliefs.

A. Quest Orientation

Quest orientation (i.e., questism) refers to an approach to religious exploration and questioning, including willingness to face complex existential thoughts, positive and critical views of religious doubt, and openness to potential change. (91) Questism was positively related to favorable perceptions of defendants, alibis, and witnesses and a higher likelihood of releasing prisoners on parole, (92) and it was negatively related to severity of sentence. (93) Quest orientation is a motivation to pursue religion as a means to question existence in various forms, yet it is still unclear how this might influence jurors' attitudes and decisions related to criminal and civil cases. Research regarding questism and juror attitudes and decisions is severely limited and more research is needed to better understand these relationships.

B. Intrinsic Religious Orientation

Intrinsic religious orientation describes the extent to which a person internalizes religion and uses religion to guide his or her morality, ethics, and judgment. (94) Intrinsic religious orientation was negatively related to reported vengefulness (95) and punitiveness toward vigilantism, (96) suggesting that intrinsically religious individuals are less accepting of punishing wrongdoers.

C. Extrinsic Religious Orientation

Extrinsic religious orientation describes the way in which a person uses religion to accumulate social resources and financial benefits. (97) Extrinsic religiosity was related to more reported vengefulness (98) and less punitive responses toward vigilantism (99) suggesting that extrinsically religious individuals are more accepting of punishing wrongdoers.


In 2010, a jury found Cisco Systems infringed on Commil USA's patent and awarded Commil $3.7 million. (100) However, the verdict was thrown out, and a new trial was granted because the counsel representing Cisco mocked the Jewish beliefs of Commil's owner and one of the patent developers, creating an "us" vs. "them" mentality to the jury. (101) Strategies such as these are often employed by attorneys to create a mindset from which jurors are then to base their perceptions of the defendant, and ultimately their verdicts. (102) These strategies are not unfounded, and social science research supports the notion that a defendant's religion might play a role in jurors' attitudes and decisions. For instance, Jewish and Christian jurors were more lenient toward defendants of their same religion, compared to defendants of the other religions, (103) and jurors were more likely to convict a defendant associated with a satanic cult compared to a defendant not associated with a cult. (104)

A defendant's own emphasis of religion might also be related to jurors' decisions, however detrimental. For example, the use of a religious defense, compared to no religious defense, was positively related to likelihood of conviction and sentence severity. (105) Furthermore, a juror's Christian-Right orientation, compared to no Christian-Right orientation, was related to more severe punishments only when the defendant used a religious defense. (106) These findings suggest that the defendant's religious beliefs, in the context of the juror's religious beliefs, play a role in juror verdicts. Understanding the complicated interplay between the two is, at this point, difficult to discern, but evidence linking the two through social science research provides a worthy beginning. The incorporation of this research into current practices could prove beneficial given the rigor and robustness of some these studies and their findings, but the questions remains, "So, now what?"


The study of religion in jurors' attitudes and decisions, though systematically researched in many areas, remains in its infancy. Although relationships between jurors' religious affiliation, beliefs, and orientation and numerous legal topics were addressed in this article, this list is not exhaustive. To summarize, jurors' and defendants' religious affiliations, beliefs, or orientations are related to jurors' legal attitudes and decisionmaking. While these relationships are theoretically driven by the underlying influence of religion on the morality of law, (107) and practically driven by doctrinal teachings and established denominational stances, (108) the overall picture is still unclear. Several extensions and future research directions could improve the field and clarify the applicability forjudges and attorneys.

A. Expanding the Breadth of the Field

Researchers need to broaden their studies to include various legal topics such as mental illness, juveniles, drugs, terrorism, and civil cases because religion might not be related to jurors' attitudes and decisions similarly across these topics. Murder cases, especially death penalty cases, are overrepresented in the current religion and juror decision-making research. (109) Too few studies assess religious beliefs and civil jurors' decisions, arguably a more likely scenario for venirepersons. This preference for criminal jurors, however, might result from the obvious moral nature of crime and the alignment with strict moral doctrine within religions, allowing for a higher likelihood of overlap between the two and significant research findings. Researchers should diversify crime and case types to provide a more complete picture of religion's role in jurors' attitudes and decisions.

Future studies on religion should further include questions regarding various religious affiliations in order to expand the knowledge about affiliation differences in juror attitudes and decisions. Researchers typically study Protestantism, Judaism, and Catholicism, likely due to the availability of members of religious affiliations. However, more attention must be given to religions such as Mormonism, Islam, Buddhism, Hinduism, Universal Unitarianism, along with non-religious affiliations such as atheism and agnosticism. Including a diverse list of religious affiliations might lead to the discovery of religious differences currently unknown. This may aid judges and attorneys during voir dire and might contribute to the current debate regarding which religion-based peremptory challenges are subject to exclusion under a Batson extension. (110)

Extending the analysis of differences between religious beliefs across religious affiliations is another gap in the current literature. For instance, fundamentalism was associated with more negative insanity defense attitudes, (111) and the death penalty, (112) but these were only studied in predominately Protestant samples. Currently, no research assesses the differential relationships between fundamentalism and jurors' decisions across numerous religions. Researchers need to examine religious characteristics as they differ across religious affiliations and relate to jurors' decisions. The assumption that religious characteristics operate the same across affiliations is both problematic and naive. Empirical evidence needs to demonstrate that these differences exist and account for the direction and strength of these differences.

The research discussed above addressed patterns of individual attitudes and behavior, but the next step is to include how those individual attitudes and behaviors play out in small groups. After all, no jury trial is decided by a single juror. Although it is important to understand the relationship between religion and jurors' attitudes and decisions prior to (or without) deliberation (initial attitudes and decisions), it is essential to study post-deliberation attitudes and decisions as well. Jury deliberations can attenuate potential juror biases; (113) for instance, juror verdicts tend to be less punitive post-deliberation than pre-deliberation, though this often depends on the strength of the case. (114) These effects are likely due to the influence jurors have on each other's attitudes and decisions. Jurors might rely on their religious beliefs in forming pre-deliberation verdict preferences; however, deliberations might reveal whether jurors' opinions are in the majority or minority, potentially leading to changes in their final post-deliberation verdicts.

Finally, little research has incorporated other religious factors such as the impact of a victim's religion (115), the exposure to religious cues (e.g., swearing in on the Bible) (116), or the use of religious defenses and attorneys' arguments. (117) Such factors might also affect jurors' attitudes and decisions and should be included in future studies.

B. Methodological Concerns

Research methodology in religion and juror decisionmaking research is neither infallible nor agreed upon by all researchers in the field. Researchers often debate on how to define religion (or religious affiliation), (118) reliability and validity of current religious measures, the use of mock jurors (rather than actual jurors), (119) and the impact of various trial characteristics. (120) Although there have been many attempts to address these issues, various concerns still arise throughout the literature.

One important methodological issue is how religious affiliation is categorized. Reports of the number of religious affiliations in the U.S. range from 100 to over 1000 different denominations. (121) However, religious denominations are often grouped together by similar theology. (122) Although this might seem efficient in practice, it could mask differences among affiliations and denominations. For instance, Protestants might include Baptists, Methodists, and Presbyterians, but there might be differences between these groups (regarding juror attitudes and decisions) that are masked when grouped together as "Protestants." Defining how affiliations are grouped is necessary in understanding and interpreting religious differences among jurors.

Another important methodological concern is the integrity of religious measures. Over time, religious measures have been improved or shortened to increase validity and reliability. (123) By improving religious measures, researchers can better understand the role of specific religious beliefs in juror attitudes and decisions. Also, there is a Judeo-Christian bias found in many of the religious measures. For instance, Biblical literalism, religious fundamentalism, evangelicalism, and evangelism all involve measures of belief in a Judeo-Christian God and, more specifically, the divinity of Jesus Christ. Measures relevant to non-Christian religious affiliations are needed to account for possible religious characteristics unique to non-Christian religions and texts. (124)

A third methodological issue is that much of the research regarding religion's role in juror decision-making uses mock juror research paradigms and college student participants. Yet, mock jurors might not accurately represent actual jurors, (125) and samples (e.g., students and community members) might differ in attitudes, perceptions of trial related information, cognitive processing, and decisions. (126) However, a recent meta-analysis in the top psychology and law journal suggests that differences between college students, community members, and venire persons in juror simulation studies might be rather small or non-existent and that legal professionals can be more confident when integrating social science research on mock jurors into their strategies and practices. (127) If concerns still arise, the solution is a two-step approach, involving the integration of both student and representative juror samples to identify areas of concern and further refining testing to bolster validity and generalizability. (128) This approach suggests using students to identify potential influences on mock juror decision-making and then testing the same relationships on a representative juror sample to see if results are consistent. (129) This would allow for direct comparisons between sample types to identify key differences and account for them when applying the findings to make policy recommendations or changes in trial strategies.

Of course, of real interest to judges and attorneys would be to assess post-deliberation jury decisions in actual cases. Reflected in the Supreme Court decision of Lockhart v. McCree, (130) simulated juror and jury studies might not bear enough resemblance to a decision made by an actual juror sworn under oath and deliberating with an actual jury. (131) Therefore, the findings cannot be used to inform such foundational constitutional questions such as that of Lockhart. (132) It would behoove mock juror researchers to better simulate actual trials, impanel representative jurors, and use realistic trial settings such as live evidence and testimony presentations and deliberations. Because social scientists cannot acquire experimental control in in actual jury trials, the use of mock jury trials are better suited to isolate and test the effects of specific juror or trial characteristics. (133) Although the findings from these studies may not exactly replicate actual trials, they can serve as a tool for adjusting and adapting trial strategies. (134) They can also provide researchers with platforms from which to use more rigorous and robust methodologies to study the effects in more valid contexts. (135) Despite some of the methodological limitations, these studies can still provide numerous valuable implications for the legal system.


Legal professionals can utilize the research presented within this review in a variety of ways. Lawyers and judges often understand that potential bias exists among jurors (136) and try to address such biases through voir dire questions. (137) If a case has religious undertones, it might be prudent to know the religious affiliation of the jurors. Questions assessing jurors' religious affiliation can reveal jurors' similarity to the defendant, which can have a profound impact on jurors' verdicts. (138) However, predicting how the combination of jurors' affiliation, beliefs, and orientations predict verdicts can be difficult. Most of the evidence to date assesses one of these religious factors independent of the others. Because jurors likely do not make decisions based on only one aspect of their religious backgrounds, it is important to understand the influence of jurors' integrated religious experiences to inform voir dire decisions. (139)

The information presented in this article can also have implications for how lawyers frame arguments. (140) Religious arguments might have more impact with religious jurors than with non-religious jurors. Furthermore, lawyers can effectively use religious arguments to help influence the jury's decisions. People high in religious fundamentalism are more likely to vote for the death penalty than life in prison; (141) they were also more likely to give harsher punishment to vigilantes. (142) Lawyers in death penalty cases could potentially frame arguments in such a way as to appeal to jurors who are high in religious fundamentalism. For instance, lawyers could appeal to the notion of an "eye-for-an-eye." The defendant killed someone and should be punished accordingly (i.e., by receiving the death penalty). By understanding these factors, lawyers can create arguments to appeal to the need for death penalty decisions.

The ideas presented within this section are brief and are not exhaustive. They are simply meant to provide a starting point for lawyers to begin thinking about how social psychological research might provide assistance in framing legal arguments and selecting jury members through the voir dire process. Lawyers should be cognizant of the religious affiliations of, not only the defendant, but also of potential jury members. If potential jurors and the defendant share similar religious beliefs, this can be advantageous to the defense but detrimental to the prosecution. On the other hand, the prosecution might benefit from ensuring that jurors and the defendant do not share similar religious beliefs. Furthermore, if the crime has religious undertones, this can impact the decisions made by religious jurors. Lawyers must consider these issues before presenting cases as such extra-legal factors can be important predictors of verdicts and sentences.


Juror attitudes and decision-making (e.g., verdicts and sentencing) are associated with jurors' religious affiliation, religious characteristics, and religious orientation and motivations. Each aspect of religion relates to jurors' attitudes and decisions in different ways. Although there is research addressing these associations, researchers have paid little attention to jury deliberation, religion's role in various types of civil trials, the use of more representative juror samples, the incorporation of situational and contextual religious factors, and the study of devotion within various affiliations and beliefs. These avenues provide the opportunity for researchers to advance the field and clarify and enhance the role of research in informing legal professionals about the effects of religion on jurors' attitudes and decision-making. The field is fruitful and young, and as long as religion exists and jurors decide verdicts, there is research to be done.

Logan A. Yelderman, Monica K. Miller, & Alicia De Vault (*)

(*) Logan A. Yelderman is an Assistant Professor of Psychology at Prairie View A&M University in Prairie View, Texas. Monica K. Miller is a Professor of Criminal Justice and a Professor of Social Psychology at the University of Nevada, Reno. Alicia De Vault is a doctoral student in the Social Psychology program at the University of Nevada, Reno.

(1) See State v. Wenthe, 822 N.W.2d 822 (Minn. Ct. App. 2012).

(2) Id. at 829.

(3) Id.

(4) See id. at 830.

(5) See id.

(6) Excerpt of Jury Trial Proceedings Regarding Dismissed Juror at 49, United States v. Brown, No. 3:16-cr-93-J-32JRK (M.D. Fla. May 15, 2017).

(7) See Albert W. Alschuler, The Supreme Court and the Jury: Voir Dire, Peremptory Challenges, and the Review of Jury Verdicts, 56 U. CHI. L. REV. 153, 153-54, 206-08 (1989).


(9) See id.

(10) Juror removal, based on religion, in the voir dire process is not allowed in all jurisdictions. See VIDMAR & HANS, supra note 8; see generally BRIAN H. BORNSTEIN & MONICA K. MILLER, GOD IN THE COURTROOM: RELIGION'S ROLE AT TRIAL 24-27 (2009); Monica K. Miller et al., Identification of Circumstances Under Which Religion Affects Each Stage of the Trial Process, 4 APPLIED PSYCHOL. CRIM. JUST. 135,140 (2008).

(11) See State v. Purcell, 18 P.3d 113, 118 (Ariz. Ct. App. 2001); see also Highler v. State, 854 N.E.2d 823, 828-29 (Ind. 2006).

(12) G. Jeffrey MacDonald, Boston Bombing Jwy Excludes Some Catholics, USA TODAY (Jan. 25, 2015, 4:50 PM),

(13) See Commonwealth v. Hernandez, No. BRCR2013-00983, 2014 WL 3738592 (Mass. Sup. July 24, 2014); see also Simpson v. State, 126 Nev. 756 (Nev. 2010).

(14) See Young v. Davis, 835 F.3d 520, 524-25 (5th Cir. 2016).

(15) See Clarence Darrow, Attorney for the Defense, ESQUIRE, May 1936, at 36-37, 211.

(16) See generally BORNSTEIN & MILLER, supra note 10, at 46-51.

(17) See Kevin D. Dougherty, Byron R. Johnson & Edward C. Poison, Recovering the Lost: Remeasuring U.S. Religious Affiliation, 46 J. FOR SCI. STUDY RELIGION 483, 484 (2007).

(18) Tom W. Smith, Classifying Protestant Denominations, 31 REV. RELIGIOUS RES. 225, 236(1990).

(19) See Darrow, supra note 15, at 43.

(20) Associated Press, Ex-Prosecutor Says He Kept Jews Off Juries, Fox NEWS (Mar. 21, 2005),

(21) See Miller et al, supra note 10, at 140.

(22) See Darrow, supra note 15, at 43; Associated Press, supra note 20.

(23) See Pew Research Center, Religious Groups' Official Positions on Capital Punishment, PEWFORUM.ORG (NOV. 4, 2009),

(24) See Darrow, supra note 15, at 37, 211.

(25) See generally Michelle Dillon, Asynchrony in Attitudes Toward Abortion and Gay Rights: The Challenge to Values Alignment, 53 J. FOR SCI. STUDY RELIGION. 1, 6-8 (2014).

(26) id.

(27) Batson v. Kentucky, 476 U.S. 79 (1986).

(28) See A. C. Johnstone, Peremptory Pragmatism: Religion and the Administration of the Batson Rule, 1998 U. CHI. LEGAL F. 441, 457 (1998); Kelly Lina Kuljol, Where Did Florida Go Wrong? Why Religion-Based Peremptory Challenges Withstand Constitutional Scrutiny, 32 STETSON L. REV. 171, 180 (2002); John H. Mansfiled, Peremptory Challenges to Jurors Based Upon or Affecting Religion, 34 SETON HALL L. REV. 435, 461-65 (2004); Gary J. Simpson & Stephen P. Garvey, Knockin' on Heaven's Door: Rethinking the Role of Religion in Death Penalty Cases, 86 CORNELL L. REV. 1090, 1093-95 (2001).

(29) Batson, 476 U.S. at 89.

(30) J.E.B. v. Alabama ex rel. T. B., 511 U.S. 127, 129 (1994).

(31) See People v. Martin, 75 Cal. Rptr. 2d 147, 148-149 (Cal. Ct. App. 1998).

(32) See id. at 150-51.

(33) See id.

(34) See id.

(35) Lynh Bui, Pr. George's Trial in Fatal Police Chase Tossed Because of Juror's Religious Beliefs, WASH. POST (Jan. 9, 2014),

(36) See VIDMAR & HANS, supra note 8, at 87; BORNSTEIN & MILLER supra note 10, at 17.

(37) See MacDonald, supra note 12.

(38) Robert Fitzgerald & Phoebe C. Ellsworth, Due Process vs. Crime Control: Death Qualification and Jury Attitudes, 8 LAW & HUM. BEHAV. 31, 46 (1984).

(39) Monica K. Miller & R. David Hayward, Religious Characteristics and the Death Penalty, 32 LAW & HUM. BEHAV. 113, 118 (2008); Joe Soss, Laura Langbein & Alan R. Metelko, Why Do White Americans Support the Death Penalty?, 65 J. POL. 397, 407 (2003).

(40) See Alicia Summers, R. David Hayward & Monica K. Miller, Death Qualification as Systematic Exclusion of Jurors with Certain Religious and Other Characteristics, 40 J. APPLIED SOC. PSYCHOL. 3218, 3229 (2010).

(41) See Thoroddur Bjarnason & Michael R. Welch, Father Knows Best: Parishes, Priests, and American Catholic Parishioners' Attitudes Toward Capital Punishment, 43 J. FOR SCI. STUDY RELIGION 103, 107 (2004).

(42) See Martin, 75 Cal. Rptr. 2d at 147.

(43) See Morgan v. Illinois, 504 U.S. 719 (1992); Wainwright vs. Witt, 470 U.S. 1039 (1985); Witherspoon v. Illinois, 391 U.S. 510 (1968).

(44) See Matthew P. West et al., The Legal and Methodological Implications of Death Qualification Operationalization, 13 APPLIED PSYCHOL. CRIM. JUST. 18 (2017).

(45) Kevin H. Wozniak & Andrew R. Lewis, Reexamining the Effect of Christian Denominational Affiliation on Death Penalty Support, 38 J. CRIM. JUST. 1082, 1087 (2010).

(46) See Miller & Hayward, supra note 39, at 118; Kevin M. O'Neil et al., Exploring the Effects of Attitudes Toward the Death Penalty on Capital Sentencing Verdicts, 10 PSYCHOL. PUB. POL'Y & L. 443, 459 (2004).

(47) Although fundamentalism can be associated with a set of religious beliefs (which will be discussed in a later section), Christian fundamentalism is also a Christian denomination or church affiliation. See Robert L. Young, Religious Orientation, Race, and Support for the Death Penalty, 31 J. SCI. STUDY RELIGION 76, 82-83 (1992). [Hereinafter, Young].

(48) See Soss, supra note 39, at 407.

(49) Note, the U.S. Supreme Court ruled that the juvenile death penalty was unconstitutional in Roper v. Simmons, 543 U.S. 551 (2005).

(50) Harold G. Grasmick et al., Religion, Punitive Justice, and Support for the Death Penalty, 10 JUST. Q. 289, 304 (1993).

(51) Theodore Eisenberg, Stephen P. Garvey & Martin T. Wells, Forecasting Life and Death: Juror Race, Religion, and Attitude Toward the Death Penalty, 30 J. LEGAL. STUD. 277, 286 (2001).

(52) Norbert L. Kerr et al., Defendant-Juror Similarity and Mock Juror Judgments, 19 L. & HUM. BEHAV. 545, 552 (1995).

(53) Valerie P. Hans & William S. Lofquist, Perceptions of Civil Justice: The Litigation Crisis Attitudes of Civil Jurors, 12 BEHAV. SCI. L. 181, 191 (1994).

(54) Dawn Michelle Baunach, Changing Same-Sex Marriage Attitudes in America from 1988 Through 2010, 76 PUB. OPINION Q. 364, 373 (2012).

(55) See BORNSTEIN & MILLER, supra note 10, at 43-51.

(56) See Bob Altemeyer & Bruce Hunsberger, Authoritarianism, Religious Fundamentalism, Quest, and Prejudice, 2 INT'L J. FOR PSYCHOL. RELIGION 113, 118 (1992) [hereinafter Altemeyer, Authoritarianism]; Bob Altemeyer & Bruce Hunsberger, A Revised Religious Fundamentalism Scale: The Short and Sweet of It, 14 INT'L J. FOR PSYCHOL. RELIGION 47, 48 (2004) [hereinafter Altemeyer, Revised]; Brandon K. Applegate et al., Forgiveness and Fundamentalism: Reconsidering the Relationship Between Correctional Attitudes and Religion, 38 CRIMINOLOGY 719, 721 (2000); Chester L. Britt, Race, Religion, and Support for the Death Penalty: A Research Note, 15 JUST. Q. 175, 178 (1998); Christopher G. Ellison & Darren E. Sherkat, Conservative Protestantism and Support for Corporal Punishment, 58 AM. SOC. REV. 131, 132, 134 (1993); Harold G. Grasmick & Anne L. McGill, Religion, Attribution Style, and Punitiveness Toward Juvenile Offenders, 32 CRIMINOLOGY 23, 25 (1994) [hereinafter Grasmick, Religion and Attribution]; Harold G. Grasmick, Robert J. Bursik, Jr. & Brenda Sims Blackwell, Religious Beliefs and Public Support for the Death Penalty for Juveniles and Adults, 16 J. CRIME & JUST. 59, 63 (1993) [hereinafter Grasmick, Religious Beliefs]; Snell Putney & Russell Middleton, Dimensions and Correlates of Religious Ideologies, 39 SOC. FORCES 285, 286 (1961); Smith, supra note 18, at 226.

(57) See MONICA K. MILLER, RELIGION IN CRIMINAL JUSTICE (2006); Britt, supra note 56, at 178; Putney & Middleton, supra note 56, at 286; see also Altemeyer, Authoritarianism, supra note 56, at 119, 130-131; Altemeyer, Revised, supra note 56, at 47-48.

(58) See BORNSTEIN & MILLER, supra note 10, at 58.

(59) See Miller & Hayward, supra note 39, at 118.

(60) Logan A. Yelderman & Monica K. Miller, Religious Fundamentalism, Religiosity, and Priming: Effects on Attitudes, Perceptions, and Mock Jurors' Decisions in an Insanity Case, 23 PSYCHOL., CRIME & L. 147, 161 (2017).

(61) T. David Evans & Mike Adams, Salvation or Damnation: Religion and Correctional Ideology, 28 AM. J. CRIM. JUST. 15, 27-29 (2003).

(62) See Miller & Hayward, supra, note 39, at 121.

(63) Monica K. Miller, Relationship Between Religious Characteristics and Responses to Vigilantism, 55 PERSONALITY & INDIVIDUAL DIFFERENCES 496, 500 (2013).

(64) Aaron J. Kivisto, & Scott A. Swan, Attitudes Toward the Insanity Defense in Capital Cases: (Im)partiality from Witherspoon to Witt, 11 J. OF FORENSIC PSYCHOL. PRACT. 311, 322 (2011); Logan A. Yelderman & Monica K. Miller, Religious Fundamentalism and Attitudes Toward the Insanity Defense: The Mediating Roles of Criminal Attributions and Attitudes Towards the Mentally ill, 23 PSYCHIATRY & PSYCHOL, OF L., 872, 873 (2016).

(65) Trevor D. Shields, Monica K. Miller & Logan A. Yelderman, Relationships Between Religious Characteristics and Response to Legal Action Against Parents Who Choose Faith Healing Practices for Their Children, 10 PSYCHOL. RELIGION & SPIRITUALITY, 88, 91 (2017).

(66) See Young, supra note 47, at 82-83; see BORNSTEIN AND MILLER, supra note 10, at 45.

(67) See Grasmick, Religion and Attribution, supra note 56, at 40.

(68) See Applegate, supra note 56, at 731; See BORNSTEIN AND MILLER, supra note 10, at 60; See Grasmick, Religious Beliefs, supra note 56, at 63; See Putney & Middleton, supra note 57, at 286; see also Evans & Adams, supra note 61, at 23; Michael J. Leiber, & Anne C. Woodrick, Religious Beliefs, Attributional Styles, and Adherence to Correctional Orientation, 24 CRIM. JUSTICE & BEHAVIOR 495, 498-99 (1997).

(69) Stephen D. Johnson, Religion as a Defense in a Mock-Jury Trial, 125 J. SOC. PSYCHOL. 213, 218 (1985).

(70) See O'Neil et al., supra note 46, at 459.

(71) See Bjarnason & Welch, supra note 41, at 107; see Young, supra note 47, at 82; see Eric P. Baumer, Steven F. Messner & Richard Rosenfeld, Explaining Spatial Variation in Support for Capital Punishment: A Multi-level Analysis, 108 AM. J. OF SOC. 844, 859 (2003); Margaret Gonzalez-Perez, A Model of Decision Making in Capital Juries, 76 INT'L SOC. SCI. REV. 79, 83 (2001). See also James D. Unnever, John P. Bartkowski & Francis T. Cullen, God Imagery and Opposition to Abortion and Capital Punishment: A Partial test of Religious Support for the Consistent life Ethic, 71 SOC. OF RELIGION 307, 313 (2010).

(72) See Evans & Adams, supra note 61, at 25-27.

(73) See Miller, supra note 63, at 499.

(74) See e.g. Evans & Adams, supra note 61, at 23; Miller, supra note 63, at 497; Putney & Middleton, supra note 56, at 286. See also Johnson, supra note 69, at 214.

(75) Young, supra note 47, at 81; BORNSTEIN AND MILLER, supra note 10, at 56; Miller, supra note 40, at 116. See Putney & Middleton, supra note 56, at 286.

(76) See Young, supra note 47, at 82; Milter et al., supra note 10, at 142; BORNSTEIN & MILLER, supra note 10; Miller & Hayward, supra note 39, at 118; see MILLER, supra note 57; Marian J. Borg, Vicarious Homicide Victimization and Support for Capital Punishment: A Test of Black's Theory of Law, 36 CRIMINOLOGY 537, 548 (1998).

(77) See Young, supra note 47, at 84-85.

(78) See Miller, supra note 63, at 499.

(79) See BORNSTEIN AND MILLER, supra note 10, at 56; Lyman A. Kellstedt, The Meaning and Measurement of Evangelicalism: Problems and Prospects, in TED G. JELEN, RELIGION AND POLITICAL BEHAVIOR IN THE UNITED STATES 3, 3-6 (Praeger, 1989).

(80) See Frank Finamore, & James M. Carlson, Religiosity, Belief in a Just World, and Crime Control Attitudes, 61 PSYCHOL. REP. 135, 136 (1987).

(81) See Grasmick, Religious Beliefs, supra note 56, at 72.

(82) See Young, supra note 47, at 81.

(83) See BORNSTEIN & MILLER, supra note 10, at 58, 59.

(84) See id; Grasmick, Religious Beliefs, supra note 56, at 63.

(85) See Grasmick, Religious Beliefs, supra note 56, at 72.

(86) See Grasmick, Religion and Attribution, supra note 56, at 37; Leiber & Woodrick, supra note 68, at 502, 504; Michael J. Leiber, Anne C. Woodrick & E. Michele Roudebush, Religion, Discriminatory Attitudes and the Orientation of Juvenile Justice Personnel: A Research Note, 33 CRIMINOLOGY 431, 441 (1995).

(87) See Miller & Hayward, supra note 39, at 119; see also MILLER, supra note 57, at 15.

(88) Gordon W. Allport & Michael J. Ross, Personal Religious Orientation and Prejudice, 5 J. PERS. SOC. PSYCHOL. 432, 434 (1967).

(89) C. Daniel Batson & Patricia A. Schoenrade, Measuring Religion as Quest: 1) Validity Concerns, 30 J. SCI. STUD. RELIGION 416, 416-17 (1991).

(90) Intrinsic and Extrinsic religious orientation are usually measured together as subscales; See Allport & Ross, supra note 88, at 436; see also Richard L. Gorsuch, & Susan E. McPherson, Intrinsic/Extrinsic Measurement: I/E-Revised and Single-Item Scales, 28 J. SCI. STUD. RELIGION 348, 349 (1989).

(91) C. Daniel Batson & Patricia A. Schoenrade, Measuring Religion as Quest: 2) Reliability Concerns, 30 J. SCI. STUDY RELIGION 430, 431 (1991).

(92) Ebeth R. Palafox, Quest and Its Relationship to Other Religious Characteristics, Legal Decisions, and Psychological Constructs (May 2010) (unpublished bachelors thesis, University of Nevada, Reno) (on file with University of Nevada, Reno).

(93) See Altemeyer, Authoritarianism, supra note 56, at 122.

(94) See Allport & Ross, supra note 88, at 434.

(95) Tammy Greer et al., We are a Religious People; We are a Vengeful People, 44 J. Sci. STUDY RELIGION 45, 53 (2005).

(96) See Miller, supra note 63, at 500.

(97) See Allport & Ross, supra note 88, at 434.

(98) See Greer et al., supra note 95, at 53.

(99) See Miller, supra note 63, at 500.

(100) Commil USA, LLC v. Cisco Systems, Inc. 135 S. Ct. 1920, 1924 (2015).

(101) Petition for Writ of Certiorari at 7, Commil, 135 S. Ct. 1920 (No. 13-896).

(102) See BORNSTEIN & MILLER, supra note 10, at 146-52.

(103) See Kerr et al., supra note 52, at 552.

(104) Jeffrey E. Pfeifer, Perceptual Biases and Mock Juror Decision Making: Minority Religions in Court, 12 SOC. JUSTICE RES. 409, 414 (1999).

(105) See Johnson, supra note 69, at 217-18.

(106) Id.

(107) Harold J. Berman, Religious Foundations of Law in the West: An Historical Perspective, 1 J.L. & RELIGION 3, 10 (1983); Philip A. Hamburger, Natural Rights, Natural Law, and American Constitutions, 102 YALE L.J. 907, 940-44 (1993); Martin E. Marty, The Religious Foundations of Law, 54 EMORY L.J. 291, 303, 307 (2005).

(108) Pew Research Center, Religious Group's Official Positions on Capital Punishment, PEW RES. CTR. (NOV. 4, 2009)

(109) See BORNSTEIN & MILLER, supra note 10, at 41-46, 58-65, 71-78; DENNIS J. DEVINE, JURY DECISION MAKING: THE STATE OF THE SCIENCE 7 (New York University Press, 2012).

(110) United States v. DeJesus, 347 F.3d 500, 511 (3d Cir. 2003).

(111) See Kivisto & Swan, supra note 64, at 322.

(112) Miller & Hayward, supra note 39, at 121.

(113) Martin F. Kaplan & Lynn E. Miller, Reducing the Effects of Juror Bias, 36 J. PERS. SOC. PSYCHOL. 1443, 1452 (1978); Robert MacCoun & Norbert L. Kerr, Asymmetric Influence in Mock Jury Deliberation: Jurors' Bias for Leniency, 54 J. PERSONALITY & SOC. PSYCHOL. 21, 29 (1988).

(114) Norbert L. Kerr et al., Bias in Jurors vs Bias in Juries: New Evidence in the SDS Perspective, 80 ORGANIZATIONAL BEHAV. & HUM. DECISION PROCESSES 70, 79-81 (1999); Monica K. Miller et al., The Effects of Deliberations and Religious Identity on Mock Jurors' Verdicts, 14 GROUP PROCESSES & INTERGROUP REL' 517, 521-22, 525 (2011).

(115) See generally Evelyn Maeder, Julie Dempsey & Joanna Pozzulo, Behind the Veil of Juror Decision Making: Testing the Effects of Muslim Veils and Defendant Race in The Courtroom, 39 CRIM. JUST. & BEHAV. 666, 672 (2012).

(116) See generally Karenna F. Malavanti et al., Subtle Contextual Influences on Racial Bias in the Courtroom, 24 THE JURY EXPERT 1, 5 (2012).

(117) See generally Monica K. Miller & Brian H. Bornstein, The Use of Religion in Death Penalty Sentencing Trials, 30 L. & HUM. BEHAV. 675, 675 (2006); see also Johnson, supra note 69.

(118) Steve Bruce, Defining Religion: A Practical Response, 21 INT'L REV. SOC. 107, 107-09 (2011).

(119) Brian H. Bornstein et al., Mock Juror Sampling Issues in Jury Simulation Research: A Meta-analysis, 41 L. & HUM. BEHAV. 21, 22 (2017).

(120) Id.

(121) See Smith, supra note 18, at 225, 229.

(122) See BORNSTEIN AND MILLER, supra note 10, at 40.

(123) See generally Altemeyer, Revised, supra note 56; see Batson & Schoenrade, supra note 89; Batson & Schoenrade, supra note 91; Gorsuch & McPherson, supra note 90.

(124) See Ziasma Haneef Khan & P. J. Watson, Construction of the Pakistani Religious Coping Practices Scale: Correlations with Religious Coping, Religious Orientation, and Reactions to Stress Among Muslim University Students, 16 INT. J. PSYCHOL. RELIGION 109 (2006); Leonardo Carlucci et al., Factor Structure of the Italian Version of the Religious Fundamentalism Scale, 112 PSYCHOL. REP. 7-8, 11-12 (2013).

(125) Richard L. Wiener et al., Mock Jury Research: Where Do We Go from Here, 29 BEHAV. SCI. & L. 467, 471 (John Wiley & Sons ed. 2011).

(126) See id. at 471; Neil Vidmar, What is the Study of Jury Decision Making About and What Should It be About, Civ. JURIES AND ClV. JUST. PSYCHOL. AND LEGAL PERSPECTIVES 67, 67 (Brian H. Bornstein et al., eds., 2008); Monica Miller et al., Relationships Between Support for the Death Penalty and Cognitive Processing: A Comparison of Students and Community Members, 41 CRIM. JUST. & BEHAV. 732, 743 (2013). See generally John G. McCabe et al., Reality Check: A Comparison of College Students and a Community Sample of Mock Jurors in a Simulated Sexual Violent Predator Civil Commitment, 28 BEHAV. SCI. & L. 730, 740 (2010).

(127) See Bornstein et al., supra note 119, at 22, 24-25.

(128) See Wiener et al., supra note 125, at 472-73; Shari Seidman Diamond, Illuminations and Shadows From Jury Simulations, 21 L. & HUM. BEHAV. 561, 563 (1997).

(129) See Wiener et al., supra note 125, at 473.

(130) Lockhart v. McCree, 476 US 162, 171 (1986).

(131) Id.

(132) ldat 172-73.

(133) See generally Diamond, supra note 128, at 563-64.

(134) Id. at 565.

(135) Id. at 566.

(136) See Alschuler supra note 7, at 153-54, 206-08.

(137) See VIDMAR & HANS, supra note 8, at 87.

(138) See Kerr et al., supra note 52, at 552.

(139) See Yelderman & Miller, supra note 60, at 161, 163.

(140) See Samuel C. Lindsey et al., How Attorneys Can Use Religion to be More Effective at Trial, 20 THE JURY EXPERT 35-38 (2008).

(141) Miller & Hayward, supra note 39, at 119.

(142) Miller, supra note 63, at 500.
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Author:Yelderman, Logan A.; Miller, Monica K.; De Vault, Alicia
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