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McDonough Power Equipment, Inc. v. Greenwood

Supreme Court of the United States · 1984 · Civil Procedure

Civil ProcedureJury SelectionVoir DireNew TrialHarmless Errorvoir direjuror nondisclosurenew trial

Facts

Respondents sued McDonough for injuries sustained when Billy Greenwood's feet came into contact with the blades of a riding lawnmower manufactured by McDonough. During voir dire, respondents' counsel asked whether any prospective juror or immediate family member had suffered a severe injury resulting in disability or prolonged pain and suffering, and juror Ronald Payton did not respond. After the jury returned a verdict for McDonough, respondents learned that Payton's son had suffered a broken leg in a tire explosion and sought to investigate the omission. The District Court allowed a limited inquiry of Payton but denied the motion for a new trial without being informed of the results of that inquiry.

Issue

When a juror fails to disclose information in response to a voir dire question, is a new trial required merely because the nondisclosure impaired a party's exercise of peremptory challenges? Or must the party instead show that the nondisclosure affected the right to an impartial jury?

Rule

To obtain a new trial based on a juror's response during voir dire, a party must demonstrate that the juror failed to answer honestly a material question on voir dire and must further show that a correct response would have provided a valid basis for a challenge for cause. A new trial is not warranted merely because the nondisclosure may have affected the exercise of peremptory challenges.

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In a federal products-liability trial in Denver, Elena Park lost to Ridgeway Outdoor Tools after a two-week jury trial. During voir dire, counsel asked whether any juror or immediate family member had ever suffered a "serious injury causing lasting pain or limitation," and juror Martin Cole stayed silent. After the verdict, Elena learned Martin's daughter had fractured her wrist years earlier, and Martin said he did not think that counted as a serious injury; Elena argues she would have used a peremptory strike on him if she had known.

Under the governing standard, is Elena entitled to a new trial?

Explanation. A new trial is not warranted merely because omitted information might have altered the use of peremptory challenges. The moving party must show that the juror failed to answer honestly a material voir dire question and that a truthful answer would have provided a valid basis for a challenge for cause. An honest mistake about an imprecise injury question does not satisfy that standard.