Dietz v. Bouldin
Issues
Can a federal court, after discharging a jury, recall the jurors and direct them to deliberate further in order to correct an invalid verdict?
This case stems from a vehicle collision lawsuit and comes to the Supreme Court on appeal from the Ninth Circuit. Respondent Hillary Bouldin collided with petitioner Rocky Dietz who subsequently sued Bouldin in Montana state court for injuries sustained during the accident. Bouldin removed the case to federal court and the jury found in favor of Dietz but erroneously awarded $0 in damages, which was legally impossible because Bouldin had admitted to causing at least $10,000 in medical expenses. The Supreme Court will clarify under which circumstances, if any, federal courts may recall jurors dismissed after having rendered a final verdict. Dietz contends that the Court should establish a bright-line rule clearly forbidding such re-empaneling of jurors, asserting instead that the appropriate remedy for an invalid verdict is a new trial. Bouldin counters that federal courts should be allowed to exercise discretion to determine when it is appropriate to recall a jury after its dismissal. This case will affect how federal courts interpret rules and procedures for recalling jurors and will also impact the fairness and finality of jury verdicts and judicial efficiency in federal court proceedings.
Questions as Framed for the Court by the Parties
After a judge has discharged a jury from service in a case and the jurors have left the judge’s presence, may the judge recall the jurors for further service in the same case?
In August 2009, respondent Hillary Bouldin, while driving his car, struck petitioner Rocky Dietz’s car. See Dietz v. Bouldin, 794 F.3d 1093, 1095 (9th Cir.
Edited by
Additional Resources
- Brandon Christian, If At First You Don’t Succeed: Understanding Judicial Doctrines of Finality, The Florida Bar Journal, Vol. 85, No. 5 (May, 2011).