Strandell v. Jackson County, Illinois

Brief Fact Summary.

Strandell’s attorney appealed a judgment holding him in contempt for refusing to participate in a nonbinding summary jury trial.

Synopsis of Rule of Law.

A federal district court cannot require parties to participate in a nonbinding summary jury trial.

Facts.

Strandell committed suicide after being arrested, strip searched, and imprisoned in Jackson County, Illinois. Strandell’s parents filed suit seeking $500,000 in damages. At a pretrial conference, the judge suggested that the parties participate in a nonbinding summary jury trial, and Strandell’s attorney refused. The Strandell’s attorney was held in criminal contempt and was subject to a fine.

Issue.

Whether a federal district court can require parties to participate in a nonbinding summary jury trial?

Held.

No. The contempt judgment is vacated. The trial court exceeded its power by forcing the parties to participate in a nonbinding summary jury trial.

Discussion.

The Federal Rules of Civil Procedure did not intend to give the court to power to force parties into settlement negotiations.