Christopher B. Dolan

In the annals of difficult clients, one stood out last year for Dolan, the founder and chief legal counsel of Dolan Law Firm. He was Ryder Vanderheyden, who suffered a brain injury when hit by a car while riding his bicycle.

That left the man with a hostile attitude that suggested a decided lack of jury appeal. Even so, in that and in a similar case, Dolan brought in seven-figure plaintiff awards.

"It affected his memory and emotional processing," Dolan said of Vanderheyden, "and caused his personality to shift significantly from a gregarious, fun guy to a very unlikeable fellow." That became evident when the man cursed Dolan shortly before he took the witness stand.

"If the damage is that the client is now unlikeable, you have to let that raw truth out and hope it comes across. It's a big risk, because generally you want the jury to like your client."

With Vanderheyden on the stand, Dolan decided to let the testimony be as harsh as his client felt. "You told me even before you came over today that you--excuse my language, your honor -- you fucking hate me and hate the fucking lawyers, correct?" Dolan asked.

"Correct," Vanderheyden answered, according to a transcript.

"The jury didn't like him, but they understood," Dolan said. They awarded Vanderheyden more than $2 million. Vanderheyden v. Jayram, RG16841708 (Alameda Super. Ct., filed Dec. 8, 2016).

In another case involving a difficult client, Dolan represented a man injured by a car that ran a stop sign obscured by a tree owned by the City of Long Beach. "This client also had a traumatic brain injury which significantly affected his personality," Dolan said, describing the condition as characterized by episodes of sudden wild and inappropriate laughing or crying. Castro v. City of Long Beach, BC604952 (L.A. Super. Ct., filed Dec. 22, 2015).

The situation tested Dolan's courtroom tactics as he tried to communicate the client's experience to the jury. "He attempted to testify once and as he sat on the stand he could only say his name, then began to cry uncontrollably," Dolan said. The judge ruled the man unavailable to provide testimony. The jury itself was a potential issue because Dolan had seated a deputy city attorney who answered a question about suing a government entity, "The king can do no wrong."

Leaving him on the jury was "a ballsy move my colleagues told me was crazy," Dolan said. "He could have been a pure ideologue and pressed for a defense verdict, but he was part of a unanimous verdict for us." The award was $4.459 million.

"I guess if you were going to sum it up," Dolan said, "my approach is: 'Trust your gut, and if you can't stomach the risk, then move over and let someone who can try the case.'"

-- John Roemer