McDonough Power Equipment, Inc. v. Greenwood et al.
464 U.S. 548 (1984)
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Rule of Law:
To obtain a new trial based on a juror's failure to disclose information during voir dire, a party must demonstrate that the juror failed to answer a material question honestly and that a correct response would have provided a valid basis for a challenge for cause.
Facts:
- Billy Greenwood's feet were severely injured by a riding lawnmower manufactured by McDonough Power Equipment, Inc.
- The Greenwood family sued McDonough for damages in a product liability action.
- During jury selection (voir dire), the Greenwoods' attorney asked all prospective jurors if they or any immediate family members had ever "sustained any severe injury ... that resulted in any disability or prolonged pain and suffering."
- Ronald Payton, a prospective juror who was later selected to serve, did not respond to this question.
- After the trial concluded, the Greenwoods discovered that Payton's son had previously suffered a broken leg from an exploding truck tire.
Procedural Posture:
- Billy Greenwood and his parents sued McDonough Power Equipment, Inc. in the U.S. District Court for the District of Kansas (a federal trial court).
- Following a trial, the jury returned a verdict in favor of McDonough.
- The District Court entered judgment for McDonough and denied the Greenwoods' motion for a new trial.
- The Greenwoods, as appellants, appealed to the U.S. Court of Appeals for the Tenth Circuit.
- The Court of Appeals reversed the District Court's judgment and ordered a new trial, holding that the juror's nondisclosure prejudiced the Greenwoods' right to peremptory challenge.
- McDonough, as petitioner, successfully sought a writ of certiorari from the U.S. Supreme Court.
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Issue:
Does a juror's failure to disclose information during voir dire, which impairs a party's ability to exercise a peremptory challenge, require a new trial without a showing that the juror's nondisclosure stemmed from dishonesty or resulted in bias sufficient for a challenge for cause?
Opinions:
Majority - Justice Rehnquist
No. A new trial is not required unless the juror's failure to disclose information demonstrates dishonesty and provides a valid basis for a challenge for cause, not merely because it impaired a peremptory challenge. A litigant is entitled to a fair trial, not a perfect one. To invalidate a lengthy trial because of a juror's mistaken, though honest, response to a question insists on a standard of perfection the judicial system cannot provide and undermines the principle of finality. The proper focus is not on the perfection of the peremptory challenge process but on securing an impartial jury. Therefore, a party moving for a new trial must demonstrate both that the juror answered dishonestly and that the correct answer would have supported a challenge for cause, meaning the juror was actually biased.
Concurring - Justice Blackmun
No. The majority opinion is correct that the central inquiry is juror impartiality. However, the Court's holding should not be read to foreclose the normal avenue for relief, which includes a trial court's option to hold a post-trial hearing to determine if a juror was actually biased or if bias should be inferred from the circumstances. This remains an option regardless of whether the juror's response was honest or dishonest.
Concurring - Justice Brennan
No. While the Court of Appeals erred, the majority's two-part test is improper. The proper focus should be on the bias of the juror and the resulting prejudice to the litigant, not strictly on the juror's honesty. A juror could provide a subjectively honest but objectively incorrect answer that nevertheless indicates bias. The juror's honesty is merely one factor to consider in determining whether, more probably than not, the juror was actually biased against the moving party.
Analysis:
This decision significantly raises the threshold for overturning a verdict based on juror nondisclosure during voir dire. It prioritizes judicial finality and efficiency over a litigant's interest in a perfectly informed jury selection process. By shifting the focus from the impairment of a peremptory challenge to the much higher standard of proving dishonesty and grounds for a challenge for cause, the Court makes it more difficult for parties to obtain a new trial. This precedent requires litigants to prove that the nondisclosure concealed actual, legally cognizable bias, rather than merely losing an opportunity to dismiss a juror based on a hunch or strategy.
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