The Skills and Abilities Required by a Personal Injury Paralegal

Lawyer and paralegal
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Personal injury paralegals assist personal injury lawyers in all aspects of personal injury litigation from case inception through appeal. Jamie Collins, a paralegal for Yosha Cook Shartzer & Tisch in Indianapolis, Indiana, and founder of The Paralegal Society relates the skills and knowledge necessary to succeed as a personal injury paralegal. Below is information on the role of paralegals in the area of personal injury law including daily responsibilities, challenges, and tips.

Client Service

A paralegal working on personal injury/wrongful death cases must know how to interview and screen prospective clients. The paralegal must review a file to determine what the client’s case involves and to determine its current status.

Medical Analysis

Personal injury paralegals must understand the medical aspects of a case to ascertain which medical records and bills to acquire and to determine if future cost projections or experts are required. The paralegal must be familiar with medical terminology and know how to prepare medical chronologies, medical expense itemizations, deposition summaries, and demand packages.

A paralegal will address prescription medications and identify which ones may be related to a client’s claim. This means understanding the typical nerve root distribution pattern for injuries involving radicular symptoms (pain that radiates from the spine into a person’s extremities), becoming familiar with the human anatomy, and gaining knowledge of various types of injuries (e.g., if they pose permanent implications or may necessitate future surgery or lifelong expenses).

Drafting Skills

Drafting skills should be part of a personal injury paralegal's capabilities. A paralegal should be able to draft discovery responses and assert all necessary objections to ensure that they are nearly perfect prior to the attorney’s review. The paralegal must also prepare witness and exhibit lists, draft motions, final instructions, verdict forms, and be ready to tackle writing projects.

Trial Preparation

Personal injury paralegals are well-versed in the trial realm. Important tasks include witness preparation (helping to prepare the clients for trial) and preparing voir dire outlines, opening and closing statements, and witness outlines. A paralegal often determines the exhibits to be used and prepares them for viewing.


Personal injury paralegals play an important role at trial. At trial, the personal injury paralegal may perform the following functions:

  • Assist the attorney with the entire voir dire process (e.g., taking notes, striking, and selection of jurors)
  • Pull and pass exhibits to the attorney as needed
  • Act as a liaison to the client throughout trial
  • Ensure the attorney does not inadvertently waive an objection during trial by allowing certain evidence to be read into the record
  • Communicate with the bailiff or court reporter if issues arise or information needs to be shared
  • Bring witnesses into the courtroom when it is their turn to testify
  • Rework exhibit binders if an exhibit is added or needs to be removed prior to presenting it to the jury (this is an event which often transpires just outside the courtroom when a last minute issue arises with an exhibit)
  • Help the attorney to elicit key pieces of testimony from each witness based upon personal knowledge of the case
  • Assist with all aspects of trial strategy and act as a second set of eyes and ears (and another legal mind) in the courtroom

It is also helpful to know the trial rules in the relevant geographic area, the Federal Rules of Civil Procedure, and the Federal Rules of Evidence for trial purposes. Trials are very exciting.

As with any area of litigation, a personal injury paralegal must also have the following characteristics:

  • An excellent multi-tasker
  • Organized and efficient
  • A proficient writer
  • Capable of prioritizing and reprioritizing tasks
  • Willing to learn new material regularly
  • Detail-oriented
  • Able to work at a fast pace
  • Accurate and consistent
  • Willing to assume full ownership of all assigned work
  • Well-spoken and personable
  • Poised and professional
  • A positive attitude