United States Supreme Court Holds that Federal Courts Have Limited Inherent Power to Recall a Jury in a Civil Case – Dietz v. Bouldin

Lawsuits arising from motor vehicle accidents rarely make it all the way to the United States Supreme Court. The vast majority of such cases are settled out of court, and only a few of those that actually reach trial are appealed. However, as a recent case shows, it is possible for a seemingly straightforward negligence case between drivers to be appealed all the way to the nation’s highest court, if one of the parties is willing to pay the legal expenses associated with such a drastic measure, and the Court is willing to hear the case.

In the case of Dietz v. Bouldin, the plaintiff and the defendant were involved in a car accident at an intersection in Bozeman, Montana. According to the plaintiff, the defendant caused the wreck by running a red light and T-boning his automobile. The plaintiff also averred that the accident caused injuries and severe pain to his lower back.

Procedure of the Case

The plaintiff filed suit against the defendant in state court. The defendant removed the suit to federal district court, presumably based upon diversity of citizenship jurisdiction. The defendant admitted that he was liable for the accident and stipulated to $10,136 in damages (the exact amount of the plaintiff’s medical expenses) but denied that the plaintiff was entitled to compensation in excess of that amount. The case was submitted to the jury on the single issue of whether the plaintiff was entitled to additional damages (for pain and suffering, etc.).

The jury deliberated for a time and then sent the judge a note inquiring as to whether the plaintiff’s medical expenses had been paid and, if they had been paid, who had paid them. The judge discussed the note with the parties’ attorneys, and it was decided that the note would be returned with an answer to the effect that the information inquired about was irrelevant to the jury’s verdict. Later, the jury returned a verdict in the plaintiff’s favor but awarded “$0” as damages. The judge discharged the jury.

After the jurors had left the courtroom, but only one had left the building, the judge realized that there was an error in the verdict and recalled the jury. After being satisfied that none of the jurors had discussed the case with anyone, the judge ordered them to return the next day. After clarifying instructions, they returned a $15,000 verdict in favor of the plaintiff. The defendant appealed. The United States Court of Appeals for the Ninth Circuit affirmed.

The United States Supreme Court’s Opinion

The court affirmed the $15,000 award to the plaintiff, holding that a federal district court has a limited inherent power to rescind an order discharging a jury and then recall that jury in a civil case for further deliberations if the judge has identified an error in the jury’s verdict. Here, the judge realized that a verdict of less than the stipulated amount would require a mistrial.

Economically, this case makes little sense. Why would the defendant (or, more likely, the defendant’s insurance company) spend thousands of dollars in legal fees to appeal a verdict that was less than $5,000 more than he admitted he owed? Someone must have wanted to make a point, or perhaps simply avoid paying the judgment for as long as possible, adding insult to the physical injuries suffered by the plaintiff in the accident that gave rise to the litigation.

Hire an Experienced Cape Cod Injury Lawyer

As this case demonstrates, complex issues can sometimes arise even in car wreck cases in which liability is obvious. The attorneys hired by automobile liability insurance companies to defend negligent drivers seem to have an endless supply of tricks up their sleeves to keep injured people and their families from receiving fair compensation. If you’ve been hurt, you need a knowledgeable, results-oriented Cape Cod car accident attorney on your side. The Law Offices of John C. Manoog, III can help. Call us at (888) 262-6664 today to schedule a free consultation of your Hyannis or Plymouth motor vehicle collision case.

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