Dietz v. Bouldin (579 U.S. 40)
U.S. Supreme Court · decided June 9, 2016 · Supreme Court Database (Spaeth)
- Citation
- 579 U.S. 40 · 136 S. Ct. 1885
- Decided
- June 9, 2016
- Term
- October Term 2015
- Vote
- 6–2
- Majority author
- Justice Sotomayor
- Issue area
- Judicial Power
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Conservative
Opinion excerpt
Justice SOTOMAYOR delivered the opinion of the Court. In this case, a jury returned a legally impermissible verdict. The trial judge did not realize the error until shortly after he excused the jury. He brought the jury back and ordered them to deliberate again to correct the mistake. The question before us is whether a federal district court can recall a jury it has discharged, or whether the court can remedy the error only by ordering a new trial. This Court now holds that a federal district court has the inherent power to rescind a jury discharge order and recall a jury for further deliberations after identifying an error in the jury's verdict. Because the potential of tainting jurors and the jury process after discharge is extraordinarily high, however, this power is limited in duration and scope, and must be exercised carefully to avoid any potential prejudice. I Petitioner Rocky Dietz was driving through an intersection in Bozeman, Montana, when Hillary Bouldin ran the red light and T-boned Dietz. As a result of the accident, Dietz suffered injuries to his lower back that caused him severe pain. He sought physical therapy, steroid injections, and other medications to treat his pain. Dietz sued Bouldin for negligence. Bouldin removed the case to Federal District Court. See 28 U.S.C. §§ 1332, 1441. At trial, Bouldin admitted that he was at fault for the accident and that…
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