Dietz v. Bouldin

Federal courts have an inherent limited power to call a jury back into the courtroom for continued deliberation after the jury has been dismissed but before the court has issued a final judgment in a civil case, however a district court should use discretion when exercising this power to ensure that the jury has not been prejudiced during the time they were dismissed.

Moments after dismissing a jury in a civil trial, a federal district court judge realized the jury had announced a legally impermissble verdict. The judge then called the jury back into the courtroom, ensured each member had not been prejudiced while they were absent, and instructed the jury to issue a legally permissible verdict. On appeal, the Court of Appeals affirmed the District Court’s right to rescind a jury and then recall the same jury in lieu of having an entirely new trial, so long as the jury has not heard or seen anything that might bias their verdict. The Supreme Court recognizes that a district court has a limited inherent power to manage its own affairs in order to ensure the right to a speedy and affordable trial. Among these inherent powers is the right to recall a jury in order to correct a minor error or legally impressible verdict. This inherent power is not unlimited however, and in order for the jury’s verdict to withstand appellate scrutiny, a district court must ensure that the jury members have not been exposed to any outside influence that could bias the members or cause them to release an unfair verdict. In order to determine if a jury has been tainted, the district court may take into consideration such factors as the length of time the jury has been outside the court, whether the jurors have had conversations with others about the case, whether the jurors have had access to cell phones or social media, and whether or not courtroom reactions to the verdict may result in emotional bias. Furthermore, allowing the court to rescind a discharge order so as to allow the jury to continue deliberation does not violate the Federal Rules of Civil Procedure and is a necessary option allowing the court to save time and money in lieu of ordering an entirely new trial. The Court’s holding is applicable to civil trials only. AFFIRMED