McDonald v. Pless

Background

Pless & Winbourne, a law firm, sued McDonald in North Carolina state court seeking $4,000 for legal services. The case was removed to federal court. A jury returned a verdict of $2,916 for the law firm after the jury foreman asked every juror to write down an amount, the numbers were added and divided by twelve, and that average was announced as the verdict. Some jurors later complained that the method was improper; others insisted on sticking to the agreement. The defendant sought a new trial, saying jurors had used this bargaining method and that jurors were willing to testify about what happened.

Reasoning

The Court addressed whether a juror may testify to impeach the jury’s verdict by describing what took place in their private deliberations. The Court declined to adopt North Carolina practice as binding in federal court, but agreed with the prevailing rule that jurors generally may not be used to attack their own verdicts. The majority explained that allowing jurors to testify would invite harassment of jurors, undermine frank discussion in the jury room, and turn private deliberations into public investigations. The opinion noted limited historical exceptions and prior cases where jury testimony was considered, but found none applicable to these facts. The trial court’s refusal to receive a juror’s testimony was therefore upheld.

Real world impact

The ruling makes it harder for losing parties to get new trials based on juror statements about internal deliberations. It protects jurors from post-trial questioning and helps keep verdicts final, even where some jurors later regret the method used.