Defeating Reptile Tactics and Stopping Nuclear Verdicts Under the 2026 Reform Statutes

Julie Karron
Julie Karron
Kelley Kronenberg

Julie Karron is a Partner and Business Unit Leader at Kelley Kronenberg. She focuses her practice on professional liability defense and civil litigation and serves as a Team Lead on the firm’s Fraud Fighters Team. She has nearly two decades of experience in complex insurance defense, commercial litigation, and professional liability defense.

Sloan L. Abernathy
Sloan L. Abernathy
Deutsch Kerrigan LLP

Sloan Abernathy is a Partner at Deutsch Kerrigan LLP in New Orleans, where he defends personal-injury, commercial auto and trucking, insurance, premises liability, product liability, and professional negligence matters. A former federal judicial law clerk and felony trial prosecutor, he pairs an early-resolution strategy with trial-ready preparation.

Live Video-Broadcast: September 30, 2026

2 hour CLE

Tuition: $195.00
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Program Summary

 

Nuclear verdicts start in discovery — not in closing argument

Post-Covid juries are returning nuclear verdicts, and plaintiffs' counsel are engineering them. Reptile tactics condition jurors to punish a defendant's conduct instead of weighing the plaintiff's actual injuries. Inflated ad damnum anchors then set the number, skewing juror valuations of non-economic damages before deliberations ever begin.

The mechanics are proven. Let a witness answer “yes” to a safety-rule question, and plaintiff's counsel testifies through your witness. Ignore the anchor, and mock jurors awarded over 430% more when plaintiffs requested $5 million instead of $250,000. Offer a counter-anchor, and non-economic awards dropped 41% while defense liability wins rose 16% to 19%.

Attendees leave with the defense playbook: four rules for reptile depositions, objections to safety-rule and danger discovery, counter-anchoring and damages models that maximize the perceived value of every dollar, and motions in limine targeting exorbitant ad damnum arguments.

Key topics to be discussed:

  • Recognizing Reptile Tactics
    How safety-rule and danger questions replace the reasonable-person standard and push jurors toward punitive-style compensatory awards.
  • Discovery Red Flags
    Spotting overbroad reptile-driven discovery early and objecting to requests that lower the plaintiff's burden of proof.
  • Witness Deposition Rules
    Four rules for reptile depositions, from “it depends” answers to leaving damages questions for lawyers and the court.
  • Anchoring Bias Evidence
    What the 1980 Zuehl study and later research show about ad damnum requests inflating non-economic awards.
  • Counter-Anchor Strategy
    When a rebuttal ad damnum cuts awards without undermining liability defenses, and why to introduce it early.
  • Damages Models & Motions
    Building perceived value into counter-anchor funds and using motions in limine against exorbitant ad damnum arguments.

This course is co-sponsored with myLawCLE.

Date / Time: September 30, 2026

  • 2:30 pm – 4:40 pm Eastern
  • 1:30 pm – 3:40 pm Central
  • 12:30 pm – 2:40 pm Mountain
  • 11:30 am – 1:40 pm Pacific

Closed-captioning available

Speakers

Julie Karron, Partner/Business Unit Leader | Kelley Kronenberg

Julie Karron is a Partner and Business Unit Leader at Kelley Kronenberg. She focuses her practice on professional liability defense and civil litigation and serves as a Team Lead on the firm’s Fraud Fighters Team. She has nearly two decades of experience in complex insurance defense, commercial litigation, and professional liability defense.

  • Education & Credentials

Julie graduated from Florida International University with a bachelor’s degree in criminal justice. She obtained her Juris Doctor from Nova Southeastern University Shepard Broad College of Law, where she was a member of the Moot Court Honor Society.

Her firm profile lists her J.D. from Nova Southeastern University, Shepard Broad College of Law (2005) and her B.S. from Florida International University (2001). She is admitted in Florida; the U.S. District Courts for the Southern, Middle, and Northern Districts of Florida; the U.S. Court of Appeals for the 11th Circuit; and the U.S. Bankruptcy Court for the Southern District of Florida.

  • Recognition & Leadership

Julie has spoken on “Traumatic Brain Injury” (February 2026), “Florida’s Tort Reform Law of 2023: Navigating Uncharted Waters,” and “Florida’s Tort Reform Law Part 2 – What You Need to Know.” Her published commentary includes “Tort Reform: Impact of HB 837 on Jury Instructions” (March 2024) and “The Dawn of Tort Reform” (March 2023).

  • Professional Involvement

She is a member of the American Bar Association, the Broward Bar Association, and the South Broward Bar Association.

  • Experience

Julie excels in managing a diverse caseload, providing proficient defense in tort and catastrophic loss, construction accidents, premises liability, and professional liability. Her extensive experience includes defending wrongful death and catastrophic loss claims, representing general contractors and subcontractors in construction defects litigation, and managing high-stakes business disputes.

In her professional liability practice, she regularly handles matters on behalf of associations, businesses, contractors, developers, business owners, and professionals, including lawyers, accountants, physicians, insurance agents, appraisers, and real estate brokers.

 

Sloan L. Abernathy, Partner | Deutsch Kerrigan LLP

Sloan Abernathy is a Partner at Deutsch Kerrigan LLP in New Orleans, where he defends personal-injury, commercial auto and trucking, insurance, premises liability, product liability, and professional negligence matters. A former federal judicial law clerk and felony trial prosecutor, he pairs an early-resolution strategy with trial-ready preparation. He is a close student of jury psychology — speaking with willing jurors after trial about how they reached their decisions — and has presented seminars and published articles on anchoring bias, reptile-strategy tactics, and the use of visual technology in response to modern juror expectations.

  • Education & Credentials

Sloan earned his J.D. from Samford University, Cumberland School of Law (2012) and his B.A. from Vanderbilt University (2009). He is admitted to practice in Louisiana and Tennessee, and before the U.S. District Courts for the Eastern, Middle, and Western Districts of Louisiana.

  • Recognition & Leadership

He has been named to the Louisiana Super Lawyers Rising Stars list since 2021, recognized in The Best Lawyers in America: Ones to Watch since 2021, and listed among New Orleans Magazine “Top Lawyers” for Personal Injury Litigation in 2025.

  • Professional Involvement

Sloan is a faculty member of the National Business Institute and presents at seminars and CLE/CE events across the country. He is a member of the Claims & Litigation Management Alliance, the Jefferson Bar Association, the Louisiana Association of Defense Counsel, the Louisiana State Bar Association, the New Orleans Bar Association, and Eagle International Associates.

  • Experience

Sloan’s courtroom results include defense verdicts in commercial-auto trials, among them Dilling v. State Farm, where he presented evidence that the plaintiffs had staged a prior “hit and run” using the same scheme. His Daubert practice has cut claimed future damages sharply — reducing potential exposure from $1.6M to $200,000 in Ozuna v. Pena and eliminating roughly half of the claimed future medical expenses in Viaud v. Express One. In Hurel v. Holton Bus, he obtained a first-impression Louisiana Fourth Circuit ruling applying the 2024 tort-reform changes to Louisiana’s Direct Action Statute, resulting in dismissal of the commercial-auto insurer he represented.

Agenda

SESSION 1 – Defending Reptile Depositions | 2:30pm – 3:30pm

This session examines reptile theory — the plaintiff tactic of conditioning jurors to prioritize safety and survival, replacing the reasonable-person standard with an “ensure safety” standard and framing a damages award as protection for the community. Ms. Karron traces how the tactic first surfaces in overbroad discovery and in safety-rule and danger questions, then presents four rules for defending reptile depositions: answers that “depend,” rejecting the simple safety rule, positioning the defendant’s conduct as reasonable, and leaving damages questions to lawyers and the court.

BREAK | 3:30pm – 3:40pm

SESSION 2 – Combating Nuclear Verdicts: Empirically Supported Strategies to Deflate the Effects of Anchoring Bias | 3:40pm – 4:40pm

In this session Mr. Abernathy examines anchoring bias — the judgmental heuristic that lets a plaintiff’s ad damnum request skew juror valuations of non-economic damages — and the empirically supported strategies proven to deflate it. He covers the research on counter-anchors, exposing and educating jurors on anchoring bias and reptile tactics, damages models that maximize the perceived value of counteranchor funds, introducing the counter-anchor early in admitted-liability cases, and motions in limine against exorbitant ad damnum arguments.

Credits

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2 General

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2 General

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2 CLE Hour(s)

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2 General

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2 General Hours

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2 General

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2 General

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2 General

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2 General

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2 Substantive

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2 CLE Hour(s)

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2 General

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2 General

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