Using Demonstrative Exhibits At Trial

It is often said that a picture is worth a thousand words. If there is a picture of an injured individual in a hospital having recently undergone major trauma, such photographic evidence truly can be worth a thousand words in demonstrating to the jury the nature and extent of the client’s injury. As an example, if someone had a serious burn injury, one can imagine the impact of such photographic evidence. Words simply cannot describe such injuries. The same is often true of photographs of demolished cars and vehicles that have been hit by large tractor trailers and/or x-rays showing broken bones in graphic detail. X-rays showing the implantation of large screws and other orthopaedic devices also can be helpful in demonstrating the extent of a clients injuries to a jury.
In some cases, where the injuries are horrific, and there is no available photographic evidence, we have retained the services of medical illustrators who can illustrate with correct anatomical detail the nature and extent of internal injuries. For example, an injury to a brain may only be partially appreciated by demonstrating (to an untrained jury) an MRI film. While a neurosurgeon might better appreciate the significance of a brain injury by interpreting the MRI film, a medical illustration may help show the damage portions of the brain caused by the trauma. Medical illustrations are also helpful in helping the jury understand the surgical techniques involved in treating serious personal injuries.
In any serious personal injury case, demonstrative exhibits, which help to demonstrate the nature and extent of the injuries sustained by the innocent client, are always helpful aids for the jury. Whether they be photographs, illustrations, computer animations or the like, any or all of the above techniques can be used by counsel to help a jury more fully appreciate the nature and extent of a client’s injuries. The better the demonstrative aid the truer the statement that a photograph is worth a thousand words. Once the jury understands and appreciates the significance of the injury, which can be demonstrated through a good demonstrative aid, words alone are no longer necessary to convince the jury of the extent of the suffering experienced by the injured client. Such aids are very helpful in obtaining adequate compensation for the injured client and, therefore, should be used where possible.