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appealtrialmotionvoir diresustainedrespondent
appealtrialvoir direrespondent

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McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548, 104 S.Ct. 845, 78 L.Ed.2d 663

Facts

Respondents Billy Greenwood and his parents sued McDonough Power Equipment after Billy was injured by a riding lawnmower. Following a three-week trial, the jury found in favor of McDonough. The respondents later claimed that a juror, Ronald Payton, failed to disclose that his son had sustained a broken leg from an exploding tire during voir dire, which they argued prejudiced their right to a peremptory challenge. The District Court denied their motion for a new trial, leading to an appeal where the Court of Appeals reversed the decision.

Respondents Billy Greenwood and his parents sued McDonough Power Equipment after Billy was injured by a riding lawnmower. Following a three-week trial, the jury found in favor of McDonough.

Issue

Did the juror's failure to disclose a family injury during voir dire warrant a new trial for the respondents?

Did the juror's failure to disclose a family injury during voir dire warrant a new trial for the respondents?

Rule

To obtain a new trial based on a juror's failure to disclose information, a party must demonstrate that the juror failed to answer honestly a material question on voir dire and that a correct response would have provided a valid basis for a challenge for cause.

To obtain a new trial based on a juror's failure to disclose information, a party must demonstrate that the juror failed to answer honestly a material question on voir dire and that a correct response would have provided a valid basis for a challenge for cause.

Analysis

The Supreme Court analyzed the juror's response and concluded that the juror's mistaken belief that his son's injury did not qualify as a severe injury did not constitute grounds for a new trial. The Court emphasized that the judicial system cannot be expected to provide perfect trials and that the focus should be on whether the juror's failure to disclose affected the fairness of the trial. The Court found that the Court of Appeals had applied an incorrect standard by automatically granting a new trial based on the juror's non-disclosure.

The Supreme Court analyzed the juror's response and concluded that the juror's mistaken belief that his son's injury did not qualify as a severe injury did not constitute grounds for a new trial.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the respondents were not entitled to a new trial based solely on the juror's failure to disclose information during voir dire.

The Supreme Court reversed the Court of Appeals' decision, holding that the respondents were not entitled to a new trial based solely on the juror's failure to disclose information during voir dire.

Who won?

McDonough Power Equipment prevailed in the case because the Supreme Court found that the juror's honest mistake did not affect the essential fairness of the trial.

McDonough Power Equipment prevailed in the case because the Supreme Court found that the juror's honest mistake did not affect the essential fairness of the trial.

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