Although jurors should make decisions based only on the law and case facts, they can be biased by extralegal factors (see e.g., Feigenson, 2000). This bias can take a number of different forms. For instance, jurors may be more lenient toward defendants seen as similar to themselves or mem-bers of their in-group (in-group bias; Kerr, Hymes, Anderson, & Weathers, 1995), and more punitive toward defendants who are members of an out-group (prejudicial bias). Alternately, jurors could be more punitive toward defendants who are members of their in-group (the “black sheep effect”; Marques, 1990).

There is an assumption that jury deliberation can “correct for” jurors’ personal biases (Kaplan & Miller, 1978). This may be particularly true for prejudicial bias, as deliberation generally tends to

The effects of deliberations and religious identity on mock jurors’ verdicts

Monica K. Miller,1 Jonathan Maskaly,2 Morgan Green3 and Clayton D. Peoples1

AbstractJurors may be biased toward defendants because of their group status or similarities/differences. Deliberation may minimize bias by forcing jurors to rationalize their decisions. In two experiments, mock jurors read that, at the time of the crime, the defendant was: engaged in Christian prayers, Islamic prayers, or TV watching (control). Study 1 described a crime stereotypically associated with Muslims (bombing a transportation center); Study 2 used a crime associated with fundamentalist Christians (bombing an abortion clinic). Participants gave predeliberation and postdeliberation verdicts. Findings for both studies are similar, despite the stereotypicality of the crime. There was a general leniency effect—the more participants saw themselves as similar to the defendant, the less certain they were of guilt. Deliberation made jurors less likely to convict Muslim and Christian defendants, but not control-group defendants. Religious identity of the defendant had no direct effect on verdicts. Findings have implications for juror bias, crime stereotypicality, and the effects of jury deliberation.

Keywords deliberation effects, crime stereotype, jury bias, leniency effect, religion

Paper received 17 November 2009; revised version accepted 8 June 2010.

1 University of Nevada, USA2 University of South Florida, USA3 Graduate of University of Nevada, Reno, USA

Corresponding author:Monica K. Miller, Criminal Justice Department and Interdisciplinary PhD Program in Social Psychology, University of Nevada, Mailstop 214, LP 105A, Reno, NV 89557, USA.Email: mkmiller@unr.edu.

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518 Group Processes & Intergroup Relations 14(4)

make jurors less punitive in criminal trials (see generally, Stasser, Kerr, & Bray, 1982). Thus, pre-deliberation juror bias may be remedied—or at least lessened—through deliberation. This could potentially result in a different verdict than if jurors did not deliberate.

There is literature on juror bias—pre- and postdeliberation—as it pertains to gender and race/ethnicity (e.g., Kerr et al., 1995). There is considerably less research, however, on juror bias related to religion. This is a significant void in the literature, as recent work shows that reli-gion can influence legal decision-making (e.g., Bornstein & Miller, 2009; Miller & Bornstein, 2006). It is possible that religious bias would be especially prevalent in cases in which the crime is stereotypically associated with certain groups (e.g., a Muslim defendant accused of bombing a transportation center or a fundamentalist Christian accused of bombing an abortion clinic). Moreover, given that nationwide surveys have revealed neg-ative attitudes toward religious minorities (particularly Muslims) since 9/11 (e.g., CNN.com, 2006), this is an important realm of poten-tial juror bias to investigate.

The purpose of the present studies is to deter-mine whether the defendant’s religious identity affects verdicts and to determine if/how deliber-ation affects this bias. Two studies will test these notions; the first uses a crime more stereotypical of Muslims, while the second study uses a crime more stereotypical of Christians. Results have important implications for the legal system and the field of psychology.

Bias in jury decisions A vast amount of research has been conducted on the effects of personal biases (e.g., gender or racial biases). Some of this stems from the early work of Sumner (1906), who argued that mem-bers of a group tend to share a sense of ethno-centrism. This ethnocentrism leads people to treat members of this in-group better than mem-bers of an out-group (see also Kerr et al., 1995). This in-group bias (and conversely, prejudicial bias against an out-group) applies across a

number of demographic dimensions including gender (Stephan, 1974), race (Bernard, 1979; Field, 1979), and political ideology (Griffit & Jackson, 1973). People make decisions benefiting members of the in-group while punishing mem-bers of the out-group (Pettigrew, 1979). These effects are not absolute, however. Sometimes group members harshly judge other members of their in-group; this is termed the “black sheep effect” (Marques, 1990). In this situation, group members try to disassociate themselves from another member by treating the other member harshly (Marques, 1990; Marques, Yzerbyt, & Leyens, 1988).

All of these biases can operate within the legal sphere—particularly within juries. Because in-group and prejudicial bias occur in the courtroom (Kerr et al., 1995), many trial consulting books advise lawyers to select jurors similar to the defendant to take advantage of in-group bias (e.g., Bailey & Rothblatt, 1985). This strategy could potentially backfire, however (Kerr et al., 1995). Jurors may treat defendants similar to themselves as black sheep, depending on the cir-cumstances of the case, increasing the likelihood of punishment for the defendant.

One possible source of bias in jury decision-making is religion, yet research has produced mixed results. The one study looking specifically at religious in-group bias found that Jewish and Christian participants were more lenient toward members of their own faith and harsher toward members of the other faith (Kerr et al., 1995). Other studies examining religious bias were not in-group studies per se; although they used largely Christian samples. One found that Christian par-ticipants were more lenient (i.e., less likely to give the death penalty) toward a defendant who had converted to Christianity, compared to a defen-dant who had not had a conversion (though only occurring when mitigating factors were present; Miller & Bornstein, 2006).

In contrast, another study revealed that a defendant was more likely to be convicted when he offered information related to his own religi-osity (Christianity) in his defense (Johnson, 1985). Johnson did not indicate the religion of his

Miller et al. 519

sample; however he found participants who frequently attended church were more punitive than those who attended more sporadically. This could indicate a black-sheep effect, assuming that the sample was largely Christian. Alternately, this could simply mean that churchgoers tend to be more conservative, and thus more punitive.

Another factor potentially affecting juror bias, particularly pertaining to religion, is the ongoing “war on terror.” The terrorist attacks of September 11, 2001 led to a negative view of Muslims, particularly within the United States (CNN.com, 2006) and perhaps increased the salience of religious background in general. Discrimination toward and poor perceptions of Muslims is sometimes called “Islamophobia” (Runnymede Trust, 1997); such sentiments increased after September 11th (Allen & Nielsen, 2002). One study found that Muslims reported a 75% increase in discrimination after September 11th (Sheridan, 2006). Although Muslims are not the only religious group experiencing discrimina-tion in the United States, they are one of the groups of interest in the current studies. Unlike research identifying discrimination toward Muslims, we were unable to locate research depicting anti-Christian attitudes in the United States. Even so, there may be a general bias against extremist Christians, especially those who commit crimes in the name of their religion.

In this climate, admitting membership in a par-ticular faith could have significant ramifications for defendants. Specifically, a particular juror may have a bias toward members of a religious out-group, which could increase the chances of a con-viction. Many of these assumptions may be partially reduced by jury deliberation.

How deliberations affect verdictsSocial scientists have long believed that delibera-tions can reduce potential biases in jury decision-making (Kaplan & Miller, 1978), including prejudicial bias. Deliberations lead jurors to become more lenient in their judgments, particu-larly in dichotomous decisions such as a guilty/not guilty verdict (see, e.g., MacCoun & Kerr,

1988). Specifically, if jurors initially support punitive verdicts because of prejudicial bias, deliberations may lead them to be less punitive (Kerr, Niedermeier, & Kaplan, 1999). Two areas of research inform this issue. The first is the comparison of the decisions of judges versus jurors; the second is the comparison of individual juror verdicts with jury verdicts.

It is likely that group decisions (e.g., jury delib-erations) may be less punitive than those reached by an individual judge. Despite the many differ-ences (e.g., expertise) between judges and juries, this comparison is relevant because jurors delib-erate while judges do not. In an early study of jury behavior, Kalven and Zeisel (1966) noted that judges and juries agreed on the verdict in 80% of cases. When there were disparities between the decisions, juries were twice as likely to acquit a defendant. This has been called the leniency bias (Kalven & Zeisel, 1966). It is possi-ble that the discrepancies in the verdicts were due in part to the different motivations and experi-ences of judges and jurors (see Champagne & Nagel, 1982). It is also possible that the leniency bias is due (at least in part) to the fact that a jury deliberates while a judge does not.

More relevant to the current studies are the studies finding that jury decisions are more lenient than juror decisions. Jury deliberation tends to lead to leniency in various circum-stances, for instance when there is no clear pre-deliberation verdict preference (Kerr, 1981). This may also occur in sentencing decisions (Davis, Kerr, Stasser, Meek, & Holt, 1977). A similar pattern is observed with jurors that mildly favor conviction (Tanford & Penrod, 1986). One study noted that, while the percent of jurors favoring conviction did not change pre- to postdeliberation, the percentage of jurors favoring acquittal did increase (Johnson, 1985). This was likely due to jurors switching from an “uncertain” predeliberation verdict to an “acquittal” postdeliberation verdict. Not all studies have observed the leniency bias (e.g., Dahl et al., 2007; Kerr, Nerenz, & Herrick, 1979); thus, deliberation may lead to leniency only in certain circumstances.

520 Group Processes & Intergroup Relations 14(4)

Overview of Study 1Study 1 sought to extend the literature regarding juror bias (e.g., religious in-group bias) and effects of deliberations. This study was a mock trial experiment that manipulated the defendant’s reli-gion via his alibi. The alibi witness testified that at the time of the crime, the defendant and witness were (a) performing Christian prayers, (b) per-forming Islamic prayers, or (c) watching televi-sion (control condition). This manipulation was designed to determine whether mock jurors would treat the defendant differently based on his religion. Christian1 mock jurors could express prejudicial bias against Muslim defendants (i.e., convicting them more often than other defen-dants) or in-group bias toward Christian defen-dants (i.e., convicting them less often). Conversely, Christian mock jurors could display the black-sheep effect (i.e., convict Christians more often). Participants were asked to provide pre- and post-deliberation verdicts and give verdict certainty scores. This research was designed to answer the following research questions:

1. Are mock jurors more lenient toward defendants they see as similar to themselves?

2. Does the defendant’s religion affect verdicts?

2a. Are Christian mock jurors either more lenient or more punitive toward in-group (Christian) defendants?

2b. Are Christian mock jurors more punitive toward out-group (Muslim) defendants?

3. Do deliberations affect jurors’ verdicts? 3a. Are verdicts more lenient postdelib-

eration compared to predeliberation? 3b. Does the deliberation process “fix”

any bias in predeliberation verdicts?

MethodCollege students read one of three mock trial scenarios describing an attempted bombing of a train station. The 1,200-word scenario included a description of the crime, testimony by witnesses, judge’s instructions, and a photograph of the

defendant (which was the same for all conditions; see Appendix). Two witnesses testified for the prosecution (a security guard and another wit-ness) and the defendant’s friend testified and offered an alibi. The scenarios were identical except for the testimony of the alibi witness, who testified that the defendant did not commit the crimes because, at the time of the crime, the defendant was at his house and the pair was: (a) performing Christian prayers, (b) performing Islamic prayers, or (c) watching television. In addition to the manipulation of the religious identity through the alibi, the names of the defen-dant and witness were congruent with the defen-dant’s faith. For instance, the Christian defendant was named John Carlson and the Muslim defen-dant was named Muhammad Hussein.

Students in social science classes (e.g., Sociology 101) participated during normal class time. They participated in groups of four to six. Participants first read the trial scenario individu-ally and indicated their individual predeliberation verdict (guilty or not guilty) and their verdict cer-tainty on a scale from 1 (very uncertain) to 5 (very certain). Participants then deliberated with their “jury” for approximately 15 minutes. After delib-erations, each participant gave individual postde-liberation verdicts and verdict certainty scores. Participants then indicated how similar they think they are to the defendant on a scale of 1 (not at all similar) to 5 (very similar) and how believable they think the defendant’s alibi is on a scale of 1 (very unbelievable) to 5 (very believable). Finally, students completed a manipulation-check ques-tion asking participants to identify the alibi used in the trial scenario.

The initial sample consisted of 194 partici-pants. This large number was gathered in an attempt to gather participants from a wide vari-ety of religious backgrounds. Ideally, the study would have a large group of Christians and a large group of Muslims in order to see if both groups showed in-group bias, black-sheep effect, etcetera. During data collection it became clear that there were not enough participants of any minority (e.g., non-Christian) religion to do any meaningful analyses comparing participants of

Miller et al. 521

different religions. Thus, we decided to limit our study to only Christian participants to determine whether this group showed bias in their deci-sions. For each of the three conditions, 35 par-ticipants were chosen randomly from a larger group of participants who marked that they were Christian (e.g., Protestant, Catholic). Those marking that they were non-Christian (e.g., Jewish, atheist) were excluded.

Results and discussionOf the 105 participants, 47% were female. They ranged in age from 18 to 27 (M = 20.22; Mdn = 20.00) and were largely Caucasian (71%) or Hispanic (19%). The manipulation check was successful, as only three participants identified the incorrect alibi. These participants were evenly distributed among the three conditions. Eliminating these participants did not affect the outcome of the study, so they were left in the final dataset.

A “predeliberation verdict certainty” variable was created by multiplying a participant’s prede-liberation verdict (−1= guilty; 1= not guilty) with certainty in that verdict (1–5 scale). Scores ranged from −5 (highly certain in a guilty verdict) to 5 (highly certain in a not-guilty verdict). The post-deliberation-verdict certainty variable was simi-larly created. This was a similar procedure as used in other jury decision-making studies (e.g., Miller & Bornstein, 2006).

Believability of alibiIn order to confirm that all the alibis were equally believable, an ANOVA was performed with alibi type as the independent variable and the question “How believable is the defendant’s alibi?” as the dependent variable. The difference between the groups was not significant (p > .05). The Christian-alibi condition was the least believable (M = 2.63), followed by the Muslim-alibi condition (M = 2.66) and the TV-alibi con-dition (M = 2.74). This analysis indicates that participants did not perceive any alibi as more believable than the others.

Similarity effectThe first research question investigated whether jurors are more lenient toward defendants who they view as similar to themselves. A positive cor-relation indicated that the more similar partici-pants saw themselves to the defendant, the more lenient they were on the verdict certainty score (i.e., less likely to convict). This occurred for both predeliberation verdict certainty (r(94) = .38, p < .001) and postdeliberation verdict certainty (r(94) = .39, p < .001).

Effects of defendant’s religious identityThe second research question assessed whether the defendant’s religious identity affected verdicts. An ANOVA was conducted using predeliberation verdict certainty as a DV (dependent variable) and defendant’s religious identity as the IV (indepen-dent variable). Results indicate that participants did not exhibit either a more lenient or punitive bias toward Christian defendants, nor a more punitive bias toward Muslim defendants, F (2, 101) = .98, p > .05. Means indicated that the Muslim defendant was the most likely to be convicted (M = −.71), followed by the Christian defendant (M = .08) and lastly the control condition(M = .37). Although this is a nonsignificant trend, the means are in the direction that would indicate bias against the Muslim defendant. A similar ANOVA using postdeliberation verdict certainty as a DV was also not significant, F (2, 102) = .61, p > .05.

Effects of deliberationThe third research question concerned the effects of deliberations on individual jurors’ verdicts and verdict certainty scores. A repeated measures ANOVA was conducted using the religious-iden-tity manipulation as the between-subjects variable and the pre- and postdeliberation verdict scores as within-participant variables. The results are presented in Figure 1.

The effect for verdict certainty was significant (F (1, 101) = 12.37, p = .001; hp

2 = .11), and means indicate that mock jurors were more

522 Group Processes & Intergroup Relations 14(4)

lenient postdeliberation (M = .79: SD = 3.34) than predeliberation (M = −.087; SD = 3.37). The interaction was also significant (F (2, 101) = 4.5, p = .014; hp

2 = .08). Specifically, this leniency effect was most pronounced in the two religious conditions. The change in the control condition from predeliberation (M = .37) to postdelibera-tion (M = .28) was not significant (p > .05), while the change in the Christian condition was signifi-cant (p = .04) from predeliberation (M = .08) to postdeliberation (M = 1.08). The Muslim condi-tion change was also significant (p = .001) from predeliberation (M = −.71) to postdeliberation (M = 1.00). This analysis indicated a general leni-ency effect in that, overall, participants became less certain in a guilty verdict and more certain in a not-guilty verdict. A follow-up analysis was con-ducted to determine if there was a change in actual verdicts, in addition to this change in ver-dict certainty scores. Fourteen of 105 participants (13%) changed their verdicts from “guilty” at

predeliberation to “not guilty” at postdeliberation. Thus, some participants changed their actual ver-dicts, in addition to changing their verdict cer-tainty scores.

The greatest change from pre- to postdelib-eration verdict was found in the Muslim condi-tion (a 1.71 point change) followed by the Christian condition (a 1.00 point change). Further, the Muslim condition showed a prede-liberation negative mean (indicating a guilty ver-dict) and a postdeliberation positive mean (indicating a not-guilty verdict). This suggests that deliberation affects verdict outcomes of this specific Muslim defendant (i.e., he would be con-victed by many individual participants before—but not after—deliberation).

In sum, findings indicate that perceptions of similarity to the defendant influence verdict cer-tainty. The more jurors perceived themselves as similar to the defendant, the less likely they were to convict. Further, religious defendants received

Post-deliberationPre-deliberation

Ver

dic

t ce

rtai

nty

1.50

1.00

0.50

0.00

–0.50

–1.00

Islamic prayerChristian prayerWatching televisionAlibi type

Figure 1. Study 1: Predeliberation and postdeliberation verdict certainty scores for each alibi type.Note: High verdict certainty scores mean greater certainty in a not-guilty verdict.

Miller et al. 523

a more lenient outcome after deliberation than before. Within religious groups, Muslim defen-dants experienced the greatest leniency effect (i.e., change between pre- and postdeliberation). It is possible that jurors are correcting for, or overcompensating for, possible prejudicial bias. Jurors were (nonsignificantly) most likely to find the Muslim defendant guilty at predeliberation. However during deliberations, jurors may not have wanted to seem biased, so they may have changed their verdict in a not-guilty direction.

These findings are limited to the current sce-nario of terrorist acts on a transportation center. It is also possible that the findings of leniency may have been stronger for Muslim defendants because this crime was more stereotypically asso-ciated with Muslims. Results may differ with crimes less associated with Muslims. Study 2 will attempt to address some of these limitations by using a different scenario.

Study 2Research has shown that jurors have precon-ceived stereotypes which could affect their ver-dicts (Stalans & Diamond, 1990). For instance, certain races are associated with certain types of crimes and not others (Hagan, 1974; Johnson, 1985). Stereotypes lead many individuals to believe that Black individuals are more likely to engage in violent street crimes (e.g., assaults, car theft) while Whites are more likely to commit white-collar crime (e.g., embezzlement, fraud) (Sunnafrank & Fontes, 1983). Additional research has shown that racial stereotypes affect mock juror decisions (Gordon, Bindrim, McNicholas, & Walden, 1988). Defendants accused of com-mitting racially stereotypical crimes (e.g., a Black male burglar or a White male embezzler) were given longer prison sentences than defendants who committed nonstereotypical crimes. There is no research, that we are aware of, examining jurors’ decisions in religiously stereotypical crimes.

Although no research has investigated religious-based crime stereotypes per se, there are negative attitudes and stereotypes associated with religious groups, especially Muslims. Followers of

the Islamic faith are typically associated with “terrorist” actions in current popular culture, particularly in the United States (Reddy, 2007). As described earlier, Study 1 found that deliberations led to significant leniency bias, and the most extreme change was found for the Muslim defen-dant. These results could potentially reflect the stereotypical nature of a Muslim bombing a transportation center (Reddy, 2007). Events such as the Madrid train bombings by Muslim terror-ists in 2004 (USA Today, 2008) have encouraged such stereotypes. There are also stereotypes asso-ciated with other religious groups. For instance, the recent shooting death of Dr. George Tiller, an abortion provider in Kansas, was committed by a member of a fundamentalist Christian sect (Stone, 2009). In 1986, Dr. Tiller’s clinic had been bombed by a fundamentalist Christian (Pilkington, 2009). Other religious fundamentalist groups (e.g., The Army of God) have taken responsibility for or have been associated with bombings of abortion clinics throughout the USA (Vita, 2003). These examples may promote the notion that fundamentalist Christians are associated with abortion clinic violence (Cooperman, 2003).

Overview of Study 2In an effort to determine if the effects found in Study 1 could be replicated under different cir-cumstances, a crime less stereotypical of a Muslim defendant was chosen. In Study 2, mock trial sce-narios were used that described an attempted bombing of an abortion clinic, a crime more ste-reotypically committed by a Christian defendant (Cooperman, 2003). The purpose of the change was to replicate the findings of Study 1 using a different trial scenario, and to determine if the most extreme pre- and postdeliberation changes would be observed in the Christian condition, because the crime was more stereotypical of that group. It is possible that the Muslim defendant would not be shown as much leniency during deliberation if the crime he is charged with is not consistent with his religious stereotype. Recall, though, that the Christian defendant was shown leniency in Study 1, even though the crime was

524 Group Processes & Intergroup Relations 14(4)

not necessarily stereotypical of his religion. Thus, this expectation is made with caution.

Study 2 was designed to test the following hypotheses:

1. As in Study 1, the more similar partici-pants believe they are to the defendant, the more likely they will be to find the defend-ant not guilty.

2. Because no in-group favoritism effect or “black-sheep effect” was found in Study 1, these effects were not expected in Study 2.

3. Based on the findings from Study 1, it is predicted that participants will be more likely to find the defendant guilty in their predeliberation verdict as compared to their postdeliberation verdict. This effect should be stronger in the Christian condi-tion for Study 2.

MethodsIn Study 2, college students read one of three trial summaries depicting an attempted bombing of an abortion clinic. The 1,200-word summary was nearly identical to that of Study 1, except for these factors: (a) the bombing was an abor-tion clinic instead of a train station and (b) addi-tional prosecution evidence (i.e., one extra witness) was added in an attempt to increase the proportion of guilty verdicts. The same alibis were used as in Study 1: performing Islamic prayers, performing Christian prayers, or watch-ing TV (control). The procedure and measures were identical to Study 1.

Results and discussionIn Study 2, researchers collected information from 67 Christian participants. As in Study 1, a manipu-lation check was conducted to determine if par-ticipants recalled the correct alibi. Seven participants identified the incorrect alibi or did not answer the question. These participants were members of two juries. Because there were other irregularities in these participants’ surveys2 these participants were eliminated to ensure the integrity

of the data. The final sample of 60 participants was 63% female and ranged in age from 18 to 38 (M = 20.53; Mdn = 19). The majority were Caucasian (70%), Hispanic (12%), or Asian/Pacific Islander (8%).

Believability of alibi The difference between groups was not significant (p > .05). The Christian-alibi condition was the least believable (M = 2.44), followed by the TV con-dition (M = 2.46) and the Muslim-alibi condi-tion (M = 3.18). This analysis indicates that participants did not perceive any alibi as more believable than any other.

Similarity effect The first analysis addressed the hypothesis that jurors are more lenient toward defendants they see like themselves. A positive correlation indicated that the more similar par-ticipants saw themselves to the defendant, the more lenient they were on the postdeliberation verdict certainty score (r(60) = .31, p = .016). This finding was identical to Study 1. This relationship was not significant in the predeliberation (r(60) = .13, p > .05) variable, unlike in Study 1.

Effects of religious identity The second analysis was designed to determine whether the defendant’s religious identity affected juror ver-dicts. This research question was addressed in the same way as in Study 1, and results were similar. The religious identity manipulation did not affect predeliberation verdict certainty scores, F(2, 57) = .13, p > .05 hp

2 = .01. The religious identity manipulation also failed to affect postdeliberation verdict certainty scores, F(2, 57) = 1.74, p > .05 hp

2 = .06.

Effects of deliberation The next set of anal-yses investigated the effects of deliberations on jurors’ verdict certainty scores. Both questions were addressed with repeated measures ANOVA, using the religious-identity condition as the between-subjects variable and the pre- and post-deliberation verdict certainty scores as the within-participant variables. Results are presented in Figure 2.

Miller et al. 525

Findings reflected those of Study 1. Overall, verdict certainty scores were significantly more lenient in postdeliberation (M = .57: SD = 3.38) than in predeliberation (M = −.07: SD = 3.27) (F (1, 57) = 6.83, p = .01; hp

2 = .11). Although Study 1 found a significant interaction between certainty verdicts and religious-identity type, this interaction in Study 2 was not significant (F (2, 57) = 2.24, p = .1; hp

2 = .07). The patterns for all three of the conditions were identical to those in Study 1, however. Participants in the Muslim-defendant condition were significantly more likely to convict the defendant predeliberation (M = .18) than postdeliberation (M = 1.47; p = .03). The Christian condition pre- (M = .06) and postdeliberation verdicts (M = 1.0; p = .04) also differed. In the TV (control) condition, pre- (M = −.32) and postdeliberation (M = −.36, p > .05) verdicts did not differ. A separate analy-sis was conducted to determine whether there was a change in participants’ dichotomous ver-dicts. Six out of 60 participants (10%) changed their verdicts from “guilty” at predeliberation to “not guilty” at postdeliberation. Thus, some par-ticipants change their verdicts, in addition to changing their verdict certainty scores.

Identical to Study 1, but counter to the expectation for Study 2, the leniency effect was stronger in the Muslim condition (a 1.29 point change) as compared to the Christian condition (a .94 point change) and the TV condition (a .04 point change). It was predicted that the Christian condition would have the greatest change, as the crime was more consistent with stereotypes of fundamentalist Christian groups. This was not supported by the current findings. Instead, simi-lar to Study 1, Muslim defendants experienced the largest leniency effect.

In general, Study 2 supports the findings of Study 1. Both studies indicate that the more jurors perceive themselves to be like the defen-dant, the more likely they are to find the defen-dant not guilty. Neither study found that the defendant’s religious identity affected verdicts, but both found that postdeliberation verdicts were more lenient than predeliberation verdicts. Both studies also found that this effect was stron-gest in the Muslim-defendant condition and also significant in the Christian condition, yet nonsig-nificant in the control condition. These findings indicate that jurors may be correcting for possible prejudicial bias toward religious defendants,

Figure 2. Study 2: Predeliberation and postdeliberation verdict certainty scores for each alibi type.Note: High verdict certainty scores mean great certainty in a not-guilty verdict.

526 Group Processes & Intergroup Relations 14(4)

whether or not the crime is stereotypical of a particular religion.

General discussionOne purpose of these studies was to determine whether Christian mock jurors demonstrate bias in their verdicts, either by being more lenient or more punitive toward religious in-group members, or being more punitive toward religious out-group members. Similarly, the studies investigated whether participants generally show leniency to defendants they see as similar to themselves. Another purpose was to determine whether deliberations lead to leni-ency and reduce bias expressed within individual predeliberation verdicts. Finally, the two studies used different crimes to determine whether the ste-reotypicality of the crime affects these results.

Perceived similarity and biasAlthough jurors did not show a significant black-sheep effect, in-group bias, or out-group bias, a general “similarity” effect was noted. Specifically, the more participants saw themselves as similar to the defendant, the more lenient their verdict. This is indicative of bias, although it does not appear to be based on religious affiliation. There are lots of nonreligious factors that may have led partici-pants to see themselves as similar to or different from the defendant—likely it was these factors that resulted in the biasing effect, not religion.

Jury deliberationOther findings align with past studies showing that deliberations affect trial outcomes (see meta-analysis by Devine, Clayton, Dunford, Seying, & Pryce, 2001). For instance, deliberation encour-ages leniency (MacCoun & Kerr, 1988), and the suppression of individual bias (Dahl et al., 2007; Kerr et al., 1999). These findings have implica-tions for several psychological phenomena: leni-ency effect, bias correction, cognitive dissonance, and crime stereotypicality. These psychological explanations can help explain the effects that

were found, and the effects found can further inform these psychological theories.

Leniency effect These studies support past research finding that deliberations lead jurors to become less punitive (MacCoun & Kerr, 1988; Sommers, 2006). In the current studies, postde-liberation verdicts were more lenient than prede-liberation verdicts. This effect was most pronounced in the Muslim-defendant condition. Leniency was also found in the Christian-defendant condition in both studies, but not in the control condition.

This leniency bias could suggest that other jurors provided arguments creating doubt as to the defendant’s guilt, or that the presence of others lead jurors to monitor their behaviors. Sommers (2006) found that more diverse juries experienced increased amounts of information during delibera-tion. This greater amount of information could lead to more lenient verdicts if it creates reason-able doubt as to the defendant’s guilt. Deliberation minimized jurors’ racially biased tendencies that occurred when the jury was not ethnically diverse. The presence of members of the defendant’s same racial group may lead other jurors to be more aware of factors (e.g., racial bias) affecting their verdict. Thus, jurors may make attempts to appear unbiased. A similar phenomenon could be at work in the current study. Jurors likely know it is inap-propriate to express prejudicial reasons for sup-porting a conviction; for instance, supporting a conviction simply because the defendant is Muslim (see e.g., Sommers & Ellsworth, 2000, 2001). A juror questioning the validity of a nonreligious alibi (e.g., watching TV) would not be subject to the same social ramifications as would a juror questioning the Muslim-prayer alibi. The process of deliberation encourages jurors to focus on non-prejudicial factors when deciding on a verdict (Shaw & Skolnick, 1995). Since jurors can no lon-ger use personal prejudice as a reason for convict-ing, they become less likely to convict.

Bias correction The findings suggest jurors may be engaging in a process called self-monitoring; specifically, they may intentionally be trying to

Miller et al. 527

avoid being, or being perceived as, biased against Muslim (and to a lesser extent, Christian) defen-dants. Bias correction is a metacognitive process that people use when attempting to avoid being improperly influenced (Wegener & Carlston, 2008). For example, Sczesny and Kühnen (2004) found that when judging leadership abilities, people are aware of and can correct for potential bias against women. Similarly, jurors may attempt to avoid being influenced by a defendant’s reli-gious affiliation when reaching a verdict because they know that religion should not influence their verdicts. Interestingly, it appears that jurors are not just correcting for bias, they are actually overcompensating. In an effort to show other jurors they are not personally prejudiced, jurors may express lenient viewpoints and verdicts (see e.g., Sommers, 2006).

Cognitive dissonance Above, it was sug-gested that deliberating jurors will hesitate to openly question the religious defendant’s alibi for fear that others will think they are prejudiced. Thus, jurors may say things that make themselves appear less punitive during deliberations. However, postdeliberation verdicts were private, thus there would be no need to justify their post-deliberation verdict to the group. Why would they become more lenient, if they do not have to jus-tify their postdeliberation verdict? One possible explanation is that, during deliberations, other jurors may have pointed out that prejudice may be an issue in the case. Becoming aware of this possibility, jurors might become more lenient because they are persuaded by others not to rely on their prejudice. Alternately, the pre- to postde-liberation leniency could be partially because of cognitive dissonance. According to the theory of cognitive dissonance, individuals who are faced with cognitive inconsistency are driven to take steps to alleviate this conflict (Festinger, 1957). Feeling personal bias internally while externally expressing the “socially correct” nonbiased stance may lead to cognitive dissonance. A juror may experience cognitive dissonance after delib-erating (Carlson & Russo, 2001). Specifically, a juror could agree with the jury’s decision of “not

guilty” only because she did not want to admit that her preference for a guilty verdict was driven by prejudice. Then, when asked to give a postde-liberation verdict, she expresses less certainty in a guilty verdict in order to reduce dissonance between the internal (prejudiced) guilty verdict and the publicly stated not-guilty verdict.

Classic cognitive dissonance studies indicate that producing arguments that advocate for a position that is counter to one’s own position actually leads to attitude change in the direction of the advocated position (Fried, 1998). In the current study, a person who feels bias toward the defendant but who expresses unbiased attitudes (so as to not appear biased), may actually change her attitude. These cognitive processes may lead to actual attitude change, as indicated by more lenient postdeliberation verdicts.

Stereotype consistency The stereotype-consistency hypothesis was not supported by the current studies. It was expected that jury delibera-tion would lead to greater leniency effect for the group that was stereotypically associated with the crime. Specifically, Study 1 findings indicate the Muslim defendant experienced the greatest pre- to postdeliberation leniency. This was thought to be a result of the stereotype that associates bombing of transportation centers with Muslims. Study 2 predicted the Christian defendant would experience the largest leniency effect, as the sce-nario was more stereotypically consistent with fundamental Christian groups. The findings did not support this prediction. Instead, the outcome of Study 2 corroborated the findings of Study 1. Both studies found that the Muslim defendant experienced greater leniency effect than defen-dants in the other conditions. These findings imply that stereotype consistency does not play as great a role in verdict outcome as expected. It is possible that people do not hold stereotypes link-ing certain crimes to a particular religious group. Considering that people hold stereotypes about certain crimes being more likely to be committed by certain racial groups, this is unlikely (Gordon et al., 1988; Hagan, 1974). It may be that other psychological factors (e.g., bias correction) are

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stronger than crime-stereotype consistencies; specifically, the need to appear unbiased in front of others may be strongest when the defendant is Muslim. Alternately, perhaps both of the crimes evoked stereotypes of both religious groups.

Limitations and future researchThere are a number of limitations that deserve mention. The current study uses data collected from a sample of mock jurors who read a short written transcript and deliberated for about 15 minutes. In contrast, real jurors expe-rience lengthy testimonies from real witnesses, see realistic and sometimes graphic evidence, and have lengthy deliberations to come to ver-dicts with real-life implications for real people. This lack of verisimilitude could mean that real jurors might not be affected in the same ways as these mock jurors. Even so, some research indicates that using mock jurors pro-duces similar results as using actual jurors or community members (e.g., Bornstein, 1999). Thus, the lack of verisimilitude may not be that big of a limitation.

Similarly, the artificially contrived mock juror scenario does not accurately replicate the conse-quentiality of the jury decision (Bornstein & McCabe, 2005). Put simply, a simulation is always going to be “pretend” despite how realistic it appears. A real-jury verdict affects the defendant’s life, while a mock jury’s decision has no real-life impact. Despite efforts to improve mock jury realism, the consequences of a jury decisions remain unmatched. As a result, real jurors may try harder (i.e., deliberate longer and think harder) than mock jurors, as their decisions have real out-comes (MacCoun, 2005). Even so, mock jurors do tend to take their task seriously (Bornstein & McCabe, 2005).

To address these limitations, realistic stimuli and scenarios with consequences should be used. For example, college students could be asked to watch a lengthy live simulation of an “actual” trial of another student accused of cheating. Participants could be led to believe the consequences for

cheating would be expulsion from the university. Participants could deliberate to a verdict similarly to this study to determine if similar results occur.

Another limitation involves the generaliz-ability of the findings. These hypotheses need to be tested in other contexts than a bombing of a train station and abortion clinic. The cur-rent studies used crimes considered stereotypi-cal of the religious groups featured in the current research. Even though the stereotypi-cality of the crime did not appear to affect the results, there is a possibility that a religiously neutral crime may produce different results. In addition, the null results may indicate that both—or neither—crimes were associated with Muslims and/or Christians; this study cannot address such issues. Future research should more directly assess stereotypicality of a variety of crimes and religions.

Another area that warrants further research is the possibility that cognitive dissonance might explain the present findings. The existence of cognitive dissonance within the jury decision-making process may explain the more lenient postdeliberation verdicts. A juror may become more lenient in an attempt to resolve the disso-nance experienced by holding different internal and external positions. As such, a juror may adjust her position, and may even overcompensate, by adopting a more positive verdict. Future studies should test this possibility.

Finally, future studies should utilize a non-Christian sample. As noted above, we tried with-out success to gain a large Muslim sample to test for in-group or out-group bias within this group. However it became clear that this was impossible given the restraints of the current available sam-ple. A future study could be conducted to remedy this by taking greater steps to secure a Muslim sample, for instance by working with a Muslim group in the community.

Despite these limitations, the current study is useful, as it presents further insight into the deci-sion-making processes of jurors. The future stud-ies suggested here can help further illuminate these effects.

Miller et al. 529

Implications for the law and legal decision-making researchIn addition to the psychological implications dis-cussed above, these studies have implications for the law and the study of legal decision-making. First, results highlight the importance of deliber-ations. While many studies ask jurors for individ-ual verdicts, the current studies allowed jurors to deliberate; deliberation significantly altered ver-dicts. Therefore, future studies should also allow jurors to deliberate, as results would better approximate real trials.

Next, it may be possible for lawyers to influence a case with pretrial selections. For instance, an attorney would likely benefit by opting for a jury trial (rather than a judge trial), especially when his/her defendant comes from a minority group which might be perceived as an out-group. In this instance, a potentially biased juror could be dissuaded from coming to a biased verdict by being forced to ratio-nalize the decision to the jury. However, in this pro-cess, a lawyer may be best advised to select jurors that see themselves as similar to the defendant in a more general sense. This strategy might have some merit with other types of out-groups including racial groups, although further research is needed.

Finally, a lawyer could also use this informa-tion to strategize the presentation of an alibi to the jury. For instance, a more controversial alibi (e.g., Muslim prayer) may be better than a more mundane alibi (such as watching television). Of course a lawyer can only alter an alibi so much without fabricating it; however if a lawyer has the choice of alibi witnesses, perhaps he should focus (or at least not avoid) a controversial witness.

ConclusionsThese two studies were designed to answer the questions of whether the defendant’s religious identity affects verdicts, whether there are various biases in juror decision-making (e.g., in-group, prej-udicial, black sheep), whether there are any effects of deliberations on jury verdicts, and whether the

stereotypicality of the crime impacts such results. While the answer to the first and last questions is a general “no,” the answer to the second and third questions is a conditional and cautious “yes.” First, there is no direct effect of defendant’s religious identity type on either pre- or postdeliberation ver-dicts. However, the interaction of religious identity and deliberations is quite interesting. A relatively mundane alibi (e.g., watching TV) is not affected by deliberation, while a relatively controversial (reli-gious) alibi is affected by deliberation such that deliberation leads to greater leniency. Second, under a particular set of circumstances, a person is likely to be more lenient toward a person perceived as similar to them. Additionally, it appears that people forced to rationalize their decision in a social situa-tion (e.g., jury deliberations) are likely to become more lenient. Paradoxically, though, jurors seemed to overcompensate to prove they are not biased.

The present study presents a somewhat less murky picture of what occurs during the jury deliberation process. Although religion plays a large part in many people’s lives, it does not appear to negatively bias jurors’ decisions. Even in a post-9/11 world in which some people are “Islamophobic,” it does not appear that being Muslim is as detrimental as one might think, even when charged with a stereotype-consistent crime. Similarly, being a Christian charged with a stereotype-consistent crime does not appear to be detrimental either. It seems that in the end, jurors will show leniency to defendants seen as more similar to them. It appears that any religious biases are actually beneficial to the defendant, as they lead to greater leniency. Inasmuch as the deliberation process is intended to promote a fair trial (e.g., by providing a verdict determined by a jury of one’s peers), it is interesting that delibera-tion increases the chances of an acquittal. Future research should further illuminate these effects in order to fully understand the relationships between religion, deliberations and verdicts.

AcknowledgmentsPreliminary analyses of Study 1 were presented at the 2009 American Psychology–Law Society Conference

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and Study 2 was presented at the 2010 Western Social Science Association Conference. The authors would like to thank Alex Sigillo, Lassette Chavez and Alayna Jehle for their help.

Notes1 We acknowledge the potential of studying other

religions, however the bulk of the present sample was Christian and therefore we focus in on this group.

2 E.g., writing sarcastic comments on the survey or leaving most questions blank

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Biographical notesmonica k. miller is Associate Professor at the University of Nevada, Reno with a dual appointment between the Interdisciplinary PhD Program in Social Psychology and the Criminal Justice Department. She received her J.D. in 2002 and her PhD in 2004 from the University of Nebraska. Her interests include jury decision-making, justice and family, and stress in the legal system.

jonathan maskaly is a PhD student in Criminology at University of South Florida, Tampa. He earned his MA in Criminal Justice

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from the University of Nevada, Reno in 2009. His current research interests include decision-making processes of law enforcement officers, advanced statistical modeling, and GIS mapping.

morgan green received her MA in Sociology from the University of Nevada, Reno in 2008 and is currently working with the Drug Court of Reno, NV as well as a program developer for inner-city youth. Areas of research include religion and health, community risk factors and health, and substance abuse prevention and treatment.

clayton d. peoples is an Assistant Professor in the Sociology Department at the University of Nevada, Reno. He is also a faculty member for the Interdisciplinary PhD Program in Social Psychology. He earned his PhD at Ohio State University in 2005. His interests include political sociology, social psychology, peace/war/social conflict, and social stratification. His recent publications have appeared in outlets such as Sociological Forum and Sociological Focus.

Appendix

Photograph of the defendant