McDonough Pwr. Equip. v. Greenwood - 464 U.S. 548 (1984)
U.S. Supreme Court
McDonough Pwr. Equip. v. Greenwood, 464 U.S. 548 (1984)
McDonough Power Equipment, Inc. v. Greenwood
Argued November 28, 1983
Decided January 18, 1984
464 U.S. 548
Respondent parents and son sued petitioner in Federal District Court to recover damages sustained by the son when his feet came in contact with the blades of a riding lawnmower manufactured by petitioner. After a trial that extended over a 3-week period, the District Court entered judgment for petitioner upon a jury verdict and denied respondents' motion for a new trial. One of the grounds alleged for a new trial was that the District Court had erred in denying respondents' motion to approach the jury after the judgment was entered because one of the jurors had not responded to a question on voir dire seeking to elicit information about previous "injuries . . . that resulted in any disability or prolonged pain or suffering" to members of the juror's immediate family when, in fact, the juror's son had sustained a broken leg as a result of an exploding tire. The Court of Appeals reversed, holding that the juror's failure to respond affirmatively to the question on voir dire had prejudiced respondents' right of peremptory challenge.
Held: Respondents are not entitled to a new trial unless the juror's failure to disclose denied them their right to an impartial jury. Courts should exercise judgment in preference to the automatic reversal for "error" and ignore errors that do not affect the essential fairness of a trial. To invalidate the result of a 3-week trial because of a juror's mistaken, though honest, response to a question, is to insist on something closer to perfection than our judicial system can be expected to give. It ill-serves the important end of finality to wipe the slate clean simply to recreate the peremptory challenge process because counsel lacked an item of information that he should have obtained from a juror on voir dire examination. The Court of Appeals' standard is contrary to the practical necessities of judicial management reflected in Federal Rule of Civil Procedure 61 and the harmless error statute, 28 U.S.C. § 2111. To obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause. Pp. 464 U. S. 553-556.
687 F.2d 338, reversed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, BLACKMUN, POWELL, STEVENS, and O'CONNOR, JJ., joined. BLACKMUN, J., filed a concurring opinion, in which STEVENS and O'CONNOR, JJ., joined, post, p. 464 U. S. 556. BRENNAN, J., filed an opinion concurring in the judgment, in which MARSHALL, J., joined, post, p. 464 U. S. 557.