Peterson v. Wilson
141 F.3d 573 (1998)
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Rule of Law:
Under Federal Rule of Evidence 606(b), a district court abuses its discretion when it grants a new trial based on information obtained from jurors during a post-verdict, ex parte meeting regarding their internal deliberations or their fidelity to the court's instructions.
Facts:
- Sylvester L. Peterson was employed as a grant director at Texas Southern University (TSU), where his employment could only be terminated for cause.
- His supervisor, Bobby Wilson, and other high-ranking administrators allegedly asked Peterson to use federal grant funds for unauthorized purposes, such as purchasing personal equipment and creating jobs for their acquaintances.
- Peterson refused these requests and claims he subsequently received implied threats of adverse job actions from Wilson.
- On January 3, 1991, Wilson terminated Peterson's employment.
- Wilson's termination letter cited nine points of "cause" based on a report prepared by another employee, Joyce Deyon.
- Evidence presented at trial suggested Wilson did not confer with Deyon about the report's contents and that the stated reasons for termination were a pretext for retaliation.
Procedural Posture:
- Sylvester L. Peterson sued Bobby Wilson and others in U.S. District Court.
- By the time of the first trial, only Peterson's substantive due process claim against Wilson remained.
- The first jury returned a verdict in favor of Peterson, awarding him damages.
- Wilson filed a renewed motion for judgment as a matter of law and an alternative motion for a new trial.
- The district court granted Wilson's motion for a new trial based on post-verdict comments from jurors.
- A second trial was held, and the jury found in favor of Wilson.
- Peterson, the plaintiff, appealed the district court's order granting the new trial to the U.S. Court of Appeals for the Fifth Circuit.
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Issue:
Does a district court abuse its discretion by granting a new trial based on comments made by jurors to the court, outside the presence of the parties, suggesting that the jury disregarded the court's instructions in reaching its verdict?
Opinions:
Majority - Wiener
Yes. A district court abuses its discretion when it grants a new trial based on information learned from post-verdict, ex parte communications with jurors regarding their thought processes. Federal Rule of Evidence 606(b) strictly prohibits a juror from testifying about any matter occurring during deliberations, including their mental processes or understanding of the court's instructions, to impeach a verdict. The only exceptions are for extraneous prejudicial information or improper outside influence, neither of which was present here. The district court explicitly stated it was granting a new trial because jurors' post-verdict comments led it to believe they had disregarded instructions, which is a direct violation of the principles established in F.R.E. 606(b) and precedent such as Tanner v. United States and Robles v. Exxon Corp. Furthermore, the court found no alternative basis to affirm the new trial order, as the jury's verdict was not against the great weight of the evidence.
Analysis:
This decision powerfully reinforces the finality of jury verdicts and the strict limitations on inquiring into jury deliberations, as mandated by Federal Rule of Evidence 606(b). It serves as a clear prohibition against trial judges engaging in ex parte, post-verdict discussions with jurors to probe the basis of their decision-making. The ruling establishes that a judge's subjective belief that the jury misunderstood or disregarded instructions, when based on such impermissible communications, constitutes a per se abuse of discretion. This precedent solidifies the 'black box' nature of jury deliberations, protecting them from judicial second-guessing and ensuring that verdicts are impeachable only under the narrow exceptions for external influence.
