Why “Before and After” Witnesses Matter at Trial

One of the most important things you can do as a trial lawyer is get to know your client.

Why Knowing Your Client Matters

Don’t just read their medical records.
Visit their home (if justified).
Learn what daily impairments they now live with.
Understand what makes them different now compared to before the injury.

Medical records are rarely detailed enough to capture the full picture of how a person’s life has changed. That’s where your own investigation — and witnesses — become crucial.

Before and After Witnesses

Every case needs what I call before and after witnesses.

These are people who:

  • Knew your client before the injury
  • Still know them after the injury

Why? Because this allows the jury to hear about your client’s struggles without making your client sound like they’re just complaining.

Example

Let’s say your client used to run five miles a day with a buddy.

At trial, instead of your client testifying:
“I can’t run anymore.”

➡️ You have their running buddy testify:
“He used to run five miles every morning with me. Since the accident, he can’t do that anymore.”

This is far more powerful — and far more credible — than having your client describe their own losses.

Why This Works

Jurors don’t want to hear a client “whining” about everything they can’t do anymore.

But when a trusted friend, coworker, or family member explains those changes, it:

  • Feels more objective
  • Carries more weight
  • Makes the jury believe it

Bottom line: Before and after witnesses can make or break how the jury perceives your client.

They transform testimony from sounding self-serving into something powerful, persuasive, and real.

For more videos, check out the Hensley Law Firm YouTube channel.

 

 

 

 

 

 

 

 

 

 

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