McDonough Power Equipment, Inc. v. Greenwood

Background

Respondents Billy Greenwood and his parents sued a lawnmower manufacturer after Billy lost both feet when his feet contacted the mower blades. A federal district court entered judgment for the manufacturer after a three-week trial and denied the Greenwoods’ motion for a new trial. After the verdict, the Greenwoods learned that juror Ronald Payton’s son had once been injured in a truck-tire explosion, a fact Payton did not reveal during jury selection, and the Tenth Circuit ordered a new trial.

Reasoning

The Supreme Court addressed whether that juror nondisclosure required a new trial. The Court held that a party is entitled to a new trial only if a juror failed to answer honestly a material jury-selection question and a truthful answer would have provided a valid basis to remove the juror for cause. The Court emphasized the need for an impartial jury, the limits of perfection in trials, harmless-error principles, and that appellate courts should usually remand factual disputes to the trial court for a hearing.

Real world impact

The ruling makes it harder to overturn verdicts based on jurors’ mistaken but honest answers and limits appellate reversal when factual development is needed. Trial courts retain discretion to hold post-trial hearings to determine actual bias. Parties who suspect juror bias must present facts showing a material, dishonest answer that would support removal for cause.

Dissents or concurrances

Justices Blackmun, Stevens, and O’Connor emphasized that trial courts may still order post-trial hearings to show actual bias. Justice Brennan agreed in the judgment but stressed focus on whether juror bias prejudiced the litigant.