Hetzel v. Prince William County

Background

A woman sued her county under federal anti-discrimination and civil-rights laws and a jury awarded her substantial damages. The district court reduced the award once because one claim was weak. The appeals court later found the jury’s damages excessive, set the award aside, and told the district court to recalculate the damages, prompting a lower damage figure on remand. When the plaintiff rejected that smaller figure and asked for a new trial on damages, the district court granted the request. The appeals court then issued a writ of mandamus directing the district court to enter a reduced judgment and blocking the retrial.

Reasoning

The Court examined whether an appeals court can force a district court to enter a lower damages judgment without giving the injured person the option to accept the smaller amount or have a new jury decide damages. Relying on the Seventh Amendment’s protection of jury findings and earlier decisions, the Court held that the appeals court’s action functioned like a remittitur but improperly removed the plaintiff’s right to choose a new trial. The Supreme Court reversed the appeals court’s mandamus order and explained that when a verdict is reduced for excessiveness, the plaintiff must be offered the choice of a new trial.

Real world impact

The ruling preserves the long-standing practice that plaintiffs may accept a reduced award or request a new jury trial when courts find jury damages excessive. It limits appellate power to substitute a judge’s damage estimate for a jury’s factual findings without offering the new-trial option. The plaintiff’s later judgment and appeals remain pending.