A combination of factors, including tort reform, a more conservative appellate bench, arbitration agreements, and increasing discovery costs, has apparently resulted in a significant decrease in resort to the civil jury trial in Texas. Trials in state court have reportedly decreased 67 percent since 1997, and U.S. district courts conducted just 135 civil jury trials in 2012, down from 360 in 1997. Product liability jury trials fell 50 percent between 2011 and 2012. While plaintiffs’ lawyers have expressed concern about the trend for more than 10 years, some defense counsel have begun calling the decline “unhealthy” and “profoundly negative.” One attorney said, “People get very upset when other constitutional rights are taken away or limited, but we are witnessing our Seventh Amendment right to a civil jury severely attacked, and people don’t seem to care.” Another said he counsels his business clients to bring their civil lawsuits in other states, noting that the Texas appellate courts so favor defendants that a good jury verdict “fully supported by the facts and the law” is likely to be reversed on appeal. See The Dallas Morning News, June 22, 2013.