United States v. Atkinson
297 U.S. 157 (1936)
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Rule of Law:
An appellate court will generally not consider an alleged error from a trial court proceeding unless the complaining party made a timely objection or exception to that error during the trial, thereby preserving the issue for appellate review.
Facts:
- A veteran, the respondent, held a United States government insurance policy for converted war risk insurance, which covered total permanent disability.
- The policy incorporated a Veterans' Administration regulation stating that 'the permanent loss of hearing of both ears...shall be deemed to be total disability.'
- The veteran suffered permanent loss of hearing in both ears.
- The veteran filed a claim with the government to receive total disability benefits under the policy, based on his loss of hearing.
Procedural Posture:
- The respondent sued the United States in a federal district court to recover benefits under an insurance policy.
- The case was tried before a jury, which received instructions from the judge that the government did not object to.
- The jury returned a verdict in favor of the respondent, and the trial court entered judgment accordingly.
- The United States, as appellant, appealed the district court's judgment to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals affirmed the judgment in favor of the respondent, who was the appellee in that court.
- The United States, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Court of Appeals' decision.
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Issue:
May an appellate court review a trial court's jury instructions for error when the complaining party failed to object to those instructions at the time of trial?
Opinions:
Majority - Mr. Justice Stone
No. An appellate court will not ordinarily set aside a verdict for an error that was not brought to the attention of the trial court. The general rule requires a party to make a timely objection or exception at trial to preserve an issue for appeal. This practice is founded upon considerations of fairness to the court and the parties, and the public interest in the finality of litigation. While appellate courts may, on their own motion, notice 'plain errors' in exceptional circumstances where the errors are obvious or seriously affect the fairness and integrity of the judicial proceedings, this case does not present such a situation. Because the government failed to object to the jury instructions at trial, it is precluded from raising the issue on appeal, and the judgment must be affirmed.
Analysis:
This decision solidifies the fundamental procedural principle of preservation of error, often called the 'raise or waive' rule. It underscores that appellate courts are primarily courts of review, not first view, and will not correct errors that the trial court was never given an opportunity to fix. The case establishes a high bar for the 'plain error' exception, limiting it to exceptional situations that threaten the fundamental fairness and integrity of the judiciary. This precedent forces litigants to be vigilant during trial and ensures that appeals are focused on contested legal rulings, rather than on mistakes that could have been easily corrected.
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