Storytelling
Storytelling · Format five

In Medias Res

Start at the decisive moment, then rewind and explain how anyone could arrive there
Texas Criminal Defense Lawyers Association · Facilitator Miguel Guhlin · Every person and case below is fictional
Fictional, and not legal advice. The lawyer, the clients, the county, and the case are invented for teaching. State v. Whitaker is not a real case and has never existed. Any resemblance to a real matter is coincidental. Nothing here is legal advice, and no fact pattern should be used as authority.

In medias res means starting in the middle. You open at the moment everything turns, before the room knows who anyone is or why it matters, and you let the not knowing do the work. What it buys you is attention before context, which is the opposite of how most lawyers talk. A room that starts with a question in its head is a room leaning in before it has decided anything, and a room that has not decided anything yet is still available to you. What it costs you is margin for error. It is easy to confuse people, and confusion reads as evasion. It fails badly when the opening moment is not genuinely decisive, because then you have promised a turn and delivered a mood. Use it in closing argument, where the room already has the facts and needs them reordered, and use it to frame a cross, where you want the jury holding one image while the witness talks around it.

The beats

Four components. Each one has a characteristic way of going wrong, and each failure happens in front of an audience rather than in your office.

Component one

The cold open

One decisive moment, in present tense, with no setup at all. No date, no procedural history, no introduction of the speaker. Names are allowed. Explanations are not. The listener should be able to see the room and should not yet understand it.

Common failure: opening on atmosphere instead of an event. A quiet courtroom is not a moment. A judge asking a question nobody can answer is a moment.
Component two

The rewind

Go back far enough to explain how a reasonable person could end up in that opening image. This is where the pressure lives: the caseload, the hour, the reason it looked fine. You are not excusing anything. You are making it recognizable.

Common failure: rewinding too far. If you go back to law school, the room loses the thread it was holding and the cold open stops paying rent.
Component three

The catch-up

Return to the exact moment you opened on, in the same words if you can, now with the room understanding what it costs. The repeated line is the payoff. It should feel heavier the second time without a single word being added.

Common failure: never coming back, or coming back with different language so the listener does not register the return and the whole structure reads as wandering.
Component four

The landing

Go past the opening moment to what it cost or what it changed. In medias res only works if the story ends somewhere the cold open could not reach. That is what makes the structure a choice rather than a trick.

Common failure: stopping at the catch-up. The room gets the reveal and no consequence, which feels clever and lands as nothing.

The story, opened cold

The same facts as every other format on this site, reordered. Read the cold open slowly, and do not explain anything until the rewind.

Forty-One Seconds

A fictional account, written for this session.

The cold open

The judge is looking at Dana Reyes over his glasses. The prosecutor is on her feet with a legal pad, not pressing, just waiting. The question was simple. Counsel, can you produce it?

She cannot produce it. Nobody can produce it. The case is called State v. Whitaker. It is on the second page of her own motion, with a year and a holding, sitting between three cases that are perfectly real. It does not exist. It has never existed.

Behind her, nineteen years old, in a borrowed shirt, Marcus Trejo is watching her back and does not know that yet. The room goes quiet. It stays quiet for about four seconds.

The rewind

Two weeks earlier, Dana was carrying forty-one open files. She practiced alone in a small Texas county. She had become a defense lawyer because of an uncle nobody showed up for, and twenty years in, she still opened every file thinking about him.

One of those files was Marcus. Possession, after a traffic stop. He was raising his younger sister. He was eight weeks from finishing a nursing assistant program that a conviction would end. He called every Friday to ask, politely, whether there was any news.

At eleven at night, two weeks out from the suppression hearing, Dana opened a chatbot and typed six words: write me a motion to suppress. What came back was clean, confident, and formatted like something she would have billed six hours for. It cited four Texas cases. Three of them were real. The fourth had a plausible name, a plausible year, and a plausible holding. She was tired. It looked right. She filed it.

The catch-up

So: the judge is looking at Dana Reyes over his glasses, and the question is still simple. Counsel, can you produce it?

She cannot. The room goes quiet, and then it moves on, and the motion is denied on its merits. Nothing on the record changes. But something else was decided in that silence, and the room felt it.

The landing

Marcus took a plea three weeks later. He lost his seat in the program. In the hallway afterward he looked at Dana, who could not look back, and said, It's okay, Ms. Reyes.

He comforted her. That was the part she could not put down.

She did not quit using AI. The problem was not the machine but the way she had used it: she had asked it to remember instead of asking it to read. So she changed two things. She stopped letting it work from memory and started handing it the record: the statute, the offense report, the dispatch log, her own prior briefs. And she added one question at the end of every session. For each claim you just made, quote the exact sentence in the material I gave you that supports it. If you cannot, mark it unsupported.

In the fall, Ruben Salas came to her. Thirty-four, a welder, two kids, charged after a stop on a frontage road. His file ran to just over three hundred pages. Dana fed the model the record and nothing else and asked it to build a timeline and flag anything that did not line up. What came back was small and unglamorous: the stop time in the offense report and the time stamped in the dispatch log were forty-one seconds apart, and the reason the officer gave for the stop appeared in the record only after the later of the two timestamps.

Dana did not file that. She opened the dispatch records herself, found the line, read it three times, and confirmed it. Then she built the argument in her own words, from the document she had now read. The court suppressed. Ruben drove himself home that afternoon.

That is the ending the cold open could not reach: a different client, the same lawyer, and one hallway she never had to stand in.

The theme

The tool did not save my client. The tool found the thread. I pulled it, and I checked it first.

Did it work?

The seven shared checks from the hub, scored 0 to 3, plus four that only matter when you start in the middle. Anything scoring 0 or 1 is where this version will break.

CheckThe question you are actually askingFails when
RetellabilityCan a listener repeat the spine in one sentence, an hour later, without notes?They summarize by listing
Record integrityDoes every beat trace to something you can actually admit into evidence?A beat needs a fact not in evidence
Emotional truthDoes it land in the body, without pushing so hard the room feels handled?Listeners resist, or go numb
Theme clarityIs there one line the room carries out the door?Three competing lines, or none
Ethical integrityDoes it mislead by implication, overclaim, or invent?It only works if nobody checks
Audience fitIs it tuned to this listener: juror, judge, prosecutor, client, or panel?One version told to everyone
ActionabilityDoes the listener know what you are asking them to do?They are moved but have no job
Decisive openIs the cold open an actual moment with an actual turn, rather than a mood or a scene setting?Nothing happens in it
Legible time jumpCan the listener feel the rewind without being handed a date, a docket, or the phrase two weeks earlier as a crutch?You have to announce it
Payoff on returnDoes the catch-up repeat the opening image closely enough that the room recognizes it and feels the weight it did not have the first time?The return goes unnoticed
Landing past the openDoes the story end somewhere the cold open could not have reached, with a cost or a change?It stops at the reveal
One rehearsal test. Tell only the cold open, then stop and ask the listener what they want to know next. If the question they ask is the question your rewind answers, the structure is working. If they ask who these people are, the open is not decisive enough to carry a delay.

Keep exploring

Hub

Storytelling for the Defense

The canonical story, all five formats, the casting exercise, and the shared seven-check rubric.

Format one

Pitch your case like a movie

The same facts told in order, opening on the image that makes a stranger care, then handing the room a job.