Jurors Can Now Be Recalled After Being Discharged

On Thursday, June 9th, 2016, the Supreme Court held in Rocky Dietz v. Hillary Bouldin (case no. 15-458) that a federal district court has the limited power to rescind a jury discharge order and recall a jury for further deliberations in civil cases after identifying an error in the verdict. The Court’s holding rests on the principles that district courts have inherent powers to manage the matters before them in an orderly and expeditious manner, though the exercise of those inherent powers must be reasonable given the problems and needs confronting the court’s fair administration of justice. Petitioner Rocky Dietz sued Hillary Bouldin for injuries resulting from an automobile accident negligently caused by Bouldin. At trial, Bouldin admitted liability to the stipulated damages of $10,136 for Dietz’ medical expenses. The jury returned a verdict in favor of Dietz, but awarded him $0 in damages. Moments after discharging the jury, the judge realized the error in the $0 verdict, and reassembled the jury. After receiving clarifying instructions from the judge, the jury awarded Dietz $15,000 in damages. In a decision written by Justice Sotomayor, the Court explained “rescinding a discharge order and recalling the jury can be a reasonable response to correcting an error in the jury’s verdict in certain circumstances,” though cautioned courts against exercising this inherent power when there was evidence that the jury had been tainted after discharge. 

Nathan A. Crane