Peterson v. Wilson

Brief Fact Summary.

Plaintiff sued Defendant (TSU’s Vice President for Academic Affairs) and others (who were no longer defendants by the time of the trial) after being fired by TSU. Jury found for Plaintiff and awarded damages. Defendant moved for a new trial. The court granted a new trial on the ground that the jury had disregarded the court’s instructions and considered improper facts in reaching its verdict. After the new trial, the jury found in favor of Defendant. Plaintiff appealed.

Synopsis of Rule of Law.

Juror testimony that the jury disregarded the court’s instructions in reaching its verdict is not a proper basis for the court’s setting aside the jury verdict.

Facts.

Plaintiff worked for Texas Southern University (TSU) as a grant director. When TSU fired Peterson, Peterson brought suit against Defendant. Plaintiff’s suit originally named other defendants as well, Defendant was the only defendant remaining in the case by the time of the trial. After a trial, the jury found for Plaintiff and awarded damages. Defendant moved for a new trial. The court granted a new trial, concluding that the jury’s verdict and comments made to the court after the verdict outside the presence of the parties or their counsel demonstrated that the jury had disregarded the court’s instructions and considered improper facts in reaching its verdict. After the new trial, the jury found in favor of Defendant. Plaintiff appealed.

Issue.

May a court impeach a jury verdict based on juror testimony that the jury disregarded the court’s instructions in reaching its verdict?

Held.

No. The court reversed the trial court’s grant of a new trial, vacated the judgment based on the verdict from the second trial, and reinstated the verdict in the first trial. The case is remanded for entry of judgment in Plaintiff’s favor based on the verdict in the first trial.

Discussion.

Juror testimony that the jury disregarded the court’s instructions in reaching its verdict is not a proper basis for the court’s setting aside the jury verdict. FRCP Rule 606(b) specifically prohibits impeachment of jury verdicts based on juror testimony relating to jurors’ mental processes or the jury’s fidelity to the court’s instructions. In other words, the court may not set aside a jury verdict based on jurors’ statements revealing the jury’s mental processes as they were deliberating the case or statements indicating that the jury disregarded the court’s instructions in reaching its verdict. Here, the court met with jurors after the trial, outside the presence of the parties or their counsel, and learned information from which it determined that the jury had disregarded its instructions. The court set aside the jury verdict and granted a new trial based on this information about the jurors’ mental processes and fidelity to its instructions. This is a per se abuse of the court’s discretion. Accordingly, the court reversed the trial court’s grant of a new trial, vacated the judgment based on the verdict from the second trial, reinstated the verdict in the first trial, and remanded the case for entry of judgment in Plaintiff’s favor.