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Supreme Court Rejects New Trial Based on Alleged Juror Bias

While many personal injury lawsuits settle without the need for a trial, plenty of cases still go before a jury. Jurors are supposed to be fair and impartial. Attorneys for both sides question prospective jurors to screen them for possible biases. But the system is not perfect. The United States Supreme Court recently dealt with a case where there was evidence of juror bias that may have unduly affected the verdict in favor of a defendant.

Warger v. Shauers

Personal injury cases, such as those arising from an automobile accident, are almost always tried under the law of the state where the accident took place. But when the parties are from different states—say, the plaintiff lives in Georgia and the defendant is an insurance company based in Delaware—the case is tried in a federal court. This means that, while the underlying negligence claim is decided according to the forum state’s laws, the rules governing the trial itself are determined by Congress and the Supreme Court.

In this case, a truck hit a man driving his motorcycle on a highway in South Dakota. As a result, the motorcycle driver lost his left leg. Both drivers blamed the other for causing the accident. The motorcycle driver ended up suing the truck driver, and the case ended up in a South Dakokta federal court.

A jury ultimately ruled in favor of the defendant truck driver. After the trial ended, one of the jurors contacted the plaintiff’s lawyer. The juror claimed that during jury deliberations, the foreperson disclosed that her daughter had previously been involved in a car accident that killed another man. The foreperson allegedly went on to say, “if her daughter had been sued, it would have ruined her life.”

Based on this information, the plaintiff asked for a new trial. The plaintiff argued the foreperson misled the court during the screening of potential jurors for bias. The judge declined to order a new trial based solely on the juror’s testimony regarding the foreperson’s alleged statements.

The Supreme Court agreed this was the right decision. In a unanimous opinion authored by Justice Sonia Sotomayor, herself a former trial judge, the Court explained that any evidence offered regarding a “statement made or incident that occurred during the jury’s deliberations” is inadmissible under federal court rules. Justice Sotomayor said this extended to statements made during deliberations that might prove a juror lied during pretrial screening. “Even if jurors lie in [pretrial questioning] in a way that conceals bias,” she explained, “juror impartiality is adequately assured by the parties’ ability to bring to the court’s attention any evidence of bias before the verdict is rendered, and to employ nonjuror evidence even after the verdict is rendered.” But the rules are clear that a party may not introduce evidence from the jury deliberations itself. Justice Sotomayor said this would “represent a threat to both jurors” and the “finality” of their verdicts.