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Damages House: A Blueprint for Building Noneconomic Damages Cases Juries Trust

Christy Crowe Childers
$135.00
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This title will ship by 1/22/27.

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Putting a dollar value on human loss can be one of the hardest things jurors are asked to do. Damages House provides an innovative method for crafting concrete and compelling noneconomic damages cases that juries immediately understand and identify with. Author and trial lawyer Christy Crowe Childers’s new model shows you how to condense complicated legal concepts into a format that is easy for juries to understand. Learn how to empower jurors to fight for your clients with this step-by-step framework for crafting a damages story that is unique, compelling, and effective.

In part one, Childers teaches a foundational approach to developing cases built combining universal concepts and storytelling techniques that are framed in the law and grounded in the evidence–an approach that not only works to invite jurors to fight for your client, it also helps protect your verdict on appeal. Childers also discusses traditional damages models and explores the benefits and shortcomings of each model in particular cases, offering examples of when the traditional models work–and when they do not (and why).

In part two, Childers begins showing you how to adopt the Damages House method based on state and case type. She offers examples of how to root the method in state laws and pattern jury instructions, and what to do when you need something more custom. With a basic framework in place, Childers then demonstrates how to start building your case by using the method to elicit case-changing testimony from your client and witnesses–including ways to inoculate against defense tricks designed to devalue your client’s loss and suffering. You will also learn how to use storytelling techniques to build your case and present your witnesses.

In part three, you will learn how to apply the Damages House method to trial and settlement negotiations. Childers demonstrates how to approach settlement negotiations, mock trials, focus groups, and mediation. You will see how mock jurors use the Damages House model to reach their verdicts both in person and in the big data focus groups Childers uses to quickly test and hone her cases. Childers will then give you everything you need to use the Damages House method in your own focus groups or mock trials so that you can make one last attempt to settle your case before opening day. Childers also discusses how to adapt the Damages House model to wrongful death cases and how these cases should be handled differently.

Finally, you will learn how to use the Damages House method in trial where Childers demonstrates the following:

  • How to use Damages House to pick the jurors that are right for your case
  • Give your project structure by using visuals to simplify and organize your case
  • Adopt the powerful three-step Damages House structure for opening statement
  • Use before and after witnesses to take the jury on a guided tour of your Damages House during direct examination
  • Take on the hardest defense witnesses in cross-examination 
  • Keep jurors’ attention and avoid turning them against you
  • A step-by-step guide to tying it all together in closing argument

Damages House offers plaintiff’s lawyers an opportunity to create winning cases in an innovative and elegant manner that makes the harm your client has suffered real and tangible for the jury. As Childers puts it, “It’s not just about numbers; it’s about justice.” 

Author

Christy Crowe Childers

Trial Lawyer

Details

Publisher: 312 pages; 1st edition (2027); ISBN: 9781951962883

Paperback: Trial Guides, LLC

Table of Contents

Publisher’s Note

Acknowledgments 

Foreword

Introduction

The Problem in a Nutshell

The Last Straw

The Epiphany

How this Book is Organized

  1. The MUSE Method
    1. Making an Epiphany
    2. But First, Let’s Find Your Muse
      1. Ingredient #1: Mindset
      2. Ingredient #2: Universals
      3. Ingredient #3: Story
    3. Mix Well and Serve
    4. Conclusion
  2. Buy Used or Build New?
    1. New Things Are Scary
      1. Step One: Thank Your Brain
      2. Step Two: Pause Your Brain
    2. Buy Used
      1. Brief Description of Each Traditional Model
    3. Build New?
    4. Conclusion
  3. What Type of House Will You Build?
    1. Choice 1: Spec Home—The Perfect (or Near Perfect) Pattern House
      1. First, Let’s Simplify your Jury Charge
      2. Going Through the Process
      3. Next, Make Sure Your Spec House Feels like Home
    2. Custom Built Home
    3. When the Rooms are Hard to Picture
    4. Conclusion
  4. Damages House Depositions
    1. Let your Client Solve Your Damages Problems. 77
    2. Before and After Witnesses. 82
      1. Have a Damages Specialist 83
      2. Show them the House. 83
      3. Dirty Defense Tricks at a Damages Deposition. 86
      4. Defense Tricks Targeting Noneconomic Damages. 91
    3. Conclusion. 96
  5. Plot Mapping
    1. The Victim’s Plot Map
    2. Plot Points
      1. Exposition: Back Story
      2. Inciting Incident: Becoming Who They’re Meant to Be
      3. Pre-Injury Conflict: Set Back
      4. Pre-Injury Rising Action: Overcame that Obstacle
      5. Main Conflict: Negligence Causes Injury—Map the Villain’s Plot
      6. Post-Injury Rising Action
      7. Climax: Verdict
      8. Falling Action: How Money Can Help
      9. Resolution: The Ending
    3. Conclusion: From Plot Map to Damages House
  6. Filling the Rooms: Casting Call, Renovations, and Witness Order
    1. Archetypes
      1. The Missing Archetype. 130
    2. Simple Casting. 131
    3. Advanced Casting. 133
    4. Putting It All Together 142
      1. Decide Who Wins Each Room.. 145
      2. Renovations. 145
      3. Witness Order 146
    5. Sequencing with Acts 148
    6. Conclusion. 151
  7. The Appraisal
    1. Appraisal Methods. 154
      1. Method #1: The Simple Multiplier Method. 154
      2. Method #2: Scaling. 157
      3. Method #3: The Dollar Amount 171
      4. Method #4: Range. 172
      5. Method #5: Economic Damages Exceptions 173
      6. Method #6: Combining Methods. 175
    2. Conclusion. 177
  8. Settlement Negotiations, Mock Trials, Focus Groups, and Mediation
    1. Please Don’t Give Away the Farm
    2. Demands and Settlement Negotiations
    3. Mock Trials/In Person Focus Groups
    4. Online Big Data Focus Groups
    5. The Write Up: Noneconomic Damages
    6. The $11 Million Ask
    7. The $33 Million Ask
    8. How to Use Damages House in Mediation Without Giving Away the Farm
    9. Conclusion
  9. Wrongful Death Damages House
    1. Death is Different
    2. Blueprint #1: The Happy Life Method
      1. Happy Life Method: Example 1
      2. Happy Life Method: Example 2
    3. Blueprint #2: The Perfect Pattern Method
    4. Blueprint #3: The Values Method
      1. The Values Method in Action
    5. Blueprint #4: The Empty House—Baby Death Cases
    6. Blueprint #5: The Last Damages House—Elderly Death Cases
    7. Blueprint #6: Dementia Damages House—When their Last House is a Memory Care Home
    8. Conclusion: Putting It All Together
  10. Trial Begins: Jury Selection
    1. Jury Selection
    2. The Three Damages Questions You Must Ask in Jury Selection
      1. Explain the Difference Between Economic and Noneconomic Damages
      2. Damages Bias Inquiry #1: Willingness to Assign Value to Noneconomic Damages
      3. Damages Bias Inquiry #2: Upper Limits Bias
      4. Damages Bias Inquiry #3: Capacity for Empathy
      5. Six Bonus Questions to Conclude
    3. Conclusion
  11. Visuals
    1. Damages House Visual
    2. Main Timeline
    3. Vertical Causation Timelines
    4. Family Timeline
    5. Conclusion
  12. The MUSE Opening Statement
    1. Framework
      1. Truth: We Always Begin with an Undeniable Truth
      2. Humanize
      3. Safe System / System Failure
      4. Plot Map
      5. Bulletproofing
      6. Damages House 
    2. Learn the Damages House Opening
      1. Step 1: Introduction (Economic versus Noneconomic Damages)
      2. Step 2: Frame It in the Law (Judge Gives Law—We Bring Evidence; More than Pain and Qualifying Language)
      3. Step 3: Ground It in the Evidence (Stories)
      4. The Ask: Appraise
    3. Conclusion
  13. Direct Examination
    1. Note Card Out Your Direct 
    2. Witness Preparation and Fortification 
    3. Presenting your Direct Examination at Trial
    4. Conclusion
  14. Cross-Examination: The MUSE Method
    1. Pre-Trial
      1. Step 1: Get Your Mind Right (Mindset)
      2. Step 2: Find Three Truths (Universal Truth)
      3. Step 3: Give the Jury Villains to Choose From (Storytelling)
    2. The MUSE Cross-Examination in Action
    3. Conclusion
  15. Closing Argument
    1. The MUSE Closing Argument
      1. First Closing
      2. First Closing Example
      3. Final Closing
      4. Final Closing Example
    2. Conclusion
    3. Final Thoughts

What Legal Leaders Are Saying

“Childers describes an original, simple, and elegant way to think and talk about noneconomic damages. But this book is so much more. It reveals the hard-won wisdom of an experienced trial lawyer who has thought deeply about how to build and defend a case for noneconomic damages. Filled with creative strategic ideas, it is also well-written—entertaining even. Any personal injury lawyer will become more effective after reading this book.”

— Rick Friedman, member of the Inner Circle of Advocates and author of The Way of the Trial Lawyer

“Christy was so gracious to help me through a death-case Damages House that is both simple and brilliant at the same time! We wrote a $90 million workable and digestible argument using Damages House that I am in love with! Thank you, Christy Crowe Childers!”

— Rachel Montes

“Damages House is revolutionary in that it condenses complicated legal concepts into a format that is easy to digest for juries in a way that ensures full compensation. And more important than the analogy is the story that is crafted through the evidence and witnesses to make that house a home. Christy’s methods have changed the way I look at damages and make full and fair compensation far easier to achieve in any case.”

— Jeremy McKenzie

“Lawyers are generally very good at following instructions, but there is no rule book for trial. (Other than the actual rules, which tell you how to get in evidence but don’t tell you how to get eight-figure verdicts). Finally, there is a method with clear guidelines and the ability to mold it to your specific facts and give the jury a framework in which to put them. The Damages House is a brilliant but simple way to tell twelve people how to value what your client went through because they are also looking for instructions. Christy made something very hard become very easy, and that’s one of the most difficult things to do.”

— Lauren Pilie

“I use Christy’s Damages House in every presentation I give to trial lawyers about appeals. It’s a great example of tying your argument to the evidence and your evidence to the law. As an appellate lawyer, having the damages tied directly to evidence at trial helps me defend the size of your verdict on appeal.”

— Danny Vincent (Appellate Lawyer)

“Every once in a while, a book comes along that makes you re-think what you have been doing in trial. Damages House will blow your mind, reset your assumptions and challenge you to powerfully present your client’s damages in a new and creative way. Damages House details novel ways to visually present human suffering and loss. It is fresh, creative, and persuasive. You will want to read this book over and over again. My copy has highlighting, tabs, and writing in the margins. This book is about way more than just damages, it’s about shaping your trial story from the very first meeting with your client. I intend to steal liberally from this book. It’s just that good. Damages House should be required reading for all plaintiffs’ lawyers. It provides easy, creative, and visually interesting step-by-step instructions on how to dramatically improve your presentation of damages evidence at trial. I cannot imagine doing another trial without using a Damages House visual.”

— Zoe Littlepage, member of the Inner Circle of Advocates and Consumer Attorneys of California 2023 Top Lawyer of the Year

Fifty-three years of trying cases, and now I have been gifted with the most extraordinary method to understand damages and losses to my clients. Christy's Damages House masterpiece is visionary in how she takes us to a new place, a new method of appreciating elements of damages—innovative steps to teach damages to judges and jurors. Her ‘Warmth-Competence-Framework’ chart focusing on how jurors trust lawyers is remarkable and taught in a way where grasping the concept is so simple and easy, and yet so powerful. Damages House is our new trial lawyers bible for litigating, mediating, and trying damages. It is the ultimate blueprint for trial victory!”

— John F. Romano, Trial Lawyers Hall of Fame Inductee and former president of the Florida Justice Association

“Childers’s book has practical advice for lawyers to lay out damages in a way that resonates with the jury. A must read for any plaintiff’s lawyer.”

— Dorothy Clay Sims, author of Exposing Deceptive Defense Doctors, has given over 350 speeches internationally on cross examination and has been featured in the Wallstreet journal and has been in four documentaries regarding her work

“Damages House is a must-read for personal injury lawyers. It takes one of the hardest things we ask jurors to do—putting a dollar value on human loss—and gives them a simple, concrete framework for doing it. This book will help you think about, and present, damages in a more persuasive way.”

— Michael Cowen, ATAA past president, board-certified truck accident attorney, host of Trial Lawyer Nation, and author of Big Rig Justice

“Christy Childers has done something truly unique. She has created a powerful way to break down—and literally illustrate—the elements of damages. Her method is simple and elegant: draw a house, then populate its rooms with elements of damages from the jury instructions. In a death case, the rooms carry their real names (living room, the kitchen, the bedroom, etc.) so that jurors don't just hear a list of legal categories; they walk through the spaces where your client lived their life. This framework turns abstract jury instructions into something jurors can picture, remember, and carry into the deliberation room. Damages House will change the way you think about, organize, and present damages.”

— Michael Leizerman, founding chair AAJ Trucking Litigation group, cofounder of the Academy of Truck Accident Attorneys, coauthor of Litigating Truck Accident Cases, partner at The Law Firm for Truck Safety

"The home is a character. Home is deeply primal. Christy Crowe Childers takes that idea beyond the abstract. She shows trial lawyers how to use the value of home to ground jurors in damages that are concrete, real, and universal. I have grown immensely from reading this book. You will too."

— Jesse Wilson, nationally recognized communication specialist, jury trial consultant, and author of Witness Preparation and The Most Important Juror

“Thank you, Christy Crowe Childers! Verdict today after five days in trial. Insurance company rejected the 300k policy demand years ago. $4.2 million verdict for my sweet and brave eighty-seven-year-old client. I used the Damages House and asked for $4.1 million. Christy was so kind to share her Damages House gems with me before trial!”

— Madeleine Simmons

“What I love about Damages House is how it takes something abstract—money for noneconomic damages—and makes it real. Nobody can picture ‘pain and suffering’ in their mind, but everyone can picture the rooms of a house. Framing it that way gives jurors something concrete to hold onto and makes it so much easier for them to put a number on it.”

— Chrissy Hagen
Trial Guides

Damages House: A Blueprint for Building Noneconomic Damages Cases Juries Trust

$135.00

Putting a dollar value on human loss can be one of the hardest things jurors are asked to do. Damages House provides an innovative method for crafting concrete and compelling noneconomic damages cases that juries immediately understand and identify with. Author and trial lawyer Christy Crowe Childers’s new model shows you how to condense complicated legal concepts into a format that is easy for juries to understand. Learn how to empower jurors to fight for your clients with this step-by-step framework for crafting a damages story that is unique, compelling, and effective.

In part one, Childers teaches a foundational approach to developing cases built combining universal concepts and storytelling techniques that are framed in the law and grounded in the evidence–an approach that not only works to invite jurors to fight for your client, it also helps protect your verdict on appeal. Childers also discusses traditional damages models and explores the benefits and shortcomings of each model in particular cases, offering examples of when the traditional models work–and when they do not (and why).

In part two, Childers begins showing you how to adopt the Damages House method based on state and case type. She offers examples of how to root the method in state laws and pattern jury instructions, and what to do when you need something more custom. With a basic framework in place, Childers then demonstrates how to start building your case by using the method to elicit case-changing testimony from your client and witnesses–including ways to inoculate against defense tricks designed to devalue your client’s loss and suffering. You will also learn how to use storytelling techniques to build your case and present your witnesses.

In part three, you will learn how to apply the Damages House method to trial and settlement negotiations. Childers demonstrates how to approach settlement negotiations, mock trials, focus groups, and mediation. You will see how mock jurors use the Damages House model to reach their verdicts both in person and in the big data focus groups Childers uses to quickly test and hone her cases. Childers will then give you everything you need to use the Damages House method in your own focus groups or mock trials so that you can make one last attempt to settle your case before opening day. Childers also discusses how to adapt the Damages House model to wrongful death cases and how these cases should be handled differently.

Finally, you will learn how to use the Damages House method in trial where Childers demonstrates the following:

Damages House offers plaintiff’s lawyers an opportunity to create winning cases in an innovative and elegant manner that makes the harm your client has suffered real and tangible for the jury. As Childers puts it, “It’s not just about numbers; it’s about justice.” 


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