Dietz v. Bouldin

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Dietz v. Bouldin
Seal of the United States Supreme Court.svg
Argued April 26, 2016
Decided June 9, 2016
Full case nameRocky Dietz, Petitioner v. Hillary Bouldin
Docket no. Expression error: Unrecognized punctuation character ""./15–458-15–458.htmExpression error: Unrecognized punctuation character "". 15–458
Citations579 U.S. ___ ( more )
136 S. Ct. 1885; 195 L. Ed. 2d 161
Opinion announcement Opinion announcement
Holding
A federal district court may rescind a discharge order and recall jurors for further service in the same case, but this power should be used cautiously. In this particular case, the judge did not abuse his authority. The judgment of the Ninth Circuit is affirmed.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan
Case opinions
MajoritySotomayor, joined by Roberts, Ginsburg, Breyer, Alito, Kagan
DissentThomas, joined by Kennedy

Dietz v. Bouldin, 579 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that a federal district court may rescind a discharge order and recall jurors for further service in the same case. [1] [2]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution. Executive acts can be struck down by the Court for violating either the Constitution or federal law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.

Contents

Background

Hillary Bouldin's vehicle collided with Rocky Dietz's in 2009 in Bozeman, Montana, and Dietz sued Bouldin for damages. Bouldin removed the case to a federal district court. During the trial, Bouldin admitted that he was negligent, and was willing to cover Dietz's medical expenses ($10,136). The point of contention was whether Dietz was entitled for more compensation. During the course of deliberation, the jury sent the judge a note whether the damages have been paid or is covered by someone else; after consulting with the lawyers in both sides, the judge informed the jury that the answer to that question does not matter. The jury ruled in favour of Dietz but awarded $0 in damages. The judge thanked and discharged the jury. However, minutes later, the judge realized that it is impossible for the damages to be $0 while Dietz won – the jury returned an invalid verdict. The judge instructed the clerk of the court to re-empanel the jury. All except for one jurors have been in the hallway; the one juror only went back to a hotel to pick up his hotel receipt; no one discussed the case with any outsider. The judge collectively questioned the jury, was satisfied with the response, and gave out clarifying instructions. The re-empaneled jury returned a verdict in favour of Dietz, with $15,000 in damages. Dietz's counsel objected to re-empanelling and pushed for a new trial. The judge objected, saying that he did not want all the resources that the court spent wasted as a result of a new trial. Dietz appealed to the United States Court of Appeals for the Ninth Circuit arguing that a judge does not have the authority to re-empanel the already-discharged jury. The Ninth Circuit ruled in favour of Bouldin. Dietz appealed to the Supreme Court of the United States and the Court granted certiorari.

Bozeman, Montana City in Montana, United States

Bozeman is a city in and the seat of Gallatin County, Montana, United States. Located in southwest Montana, the 2010 census put Bozeman's population at 37,280 and by 2016 the population rose to 45,250, making it the fourth largest city in Montana. It is the principal city of the Bozeman, MT Micropolitan Statistical Area, consisting of all of Gallatin County with a population of 97,304. It is the largest Micropolitan Statistical Area in Montana and is the third largest of all of Montana's statistical areas.

United States Court of Appeals for the Ninth Circuit Federal court with appellate jurisdiction over the districts of Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon and Washington

The United States Court of Appeals for the Ninth Circuit is a court of appeal that has appellate jurisdiction over the district courts in the following districts:

Opinion of the Court

Associate Justice Sonia Sotomayor authored the majority opinion affirming the Ninth Circuit's judgment. [2] The court ruled 6-2 that a judge may recall an already-discharged jury, but has limited authority to do so. They also ruled that this power should be used with caution. The Court noted that since in the era of smartphones and the internet it is not uncommon for people to instinctively check their phones. Thus it is possible for a discharged juror to develop potential prejudice while communicating about the case with someone else via text messages, or quickly Googling about the case to obtain more information about the case. Finally, the Court ruled that in this particular case, the trial judge did not abuse his authority.

Associate Justice of the Supreme Court of the United States member of the U.S. Supreme Court other than the Chief Justice

Associate Justice of the Supreme Court of the United States is the title of all members of the Supreme Court of the United States other than the Chief Justice of the United States. The number of associate justices is eight, as set by the Judiciary Act of 1869.

Sonia Sotomayor U.S. Supreme Court Justice

Sonia Maria Sotomayor is an Associate Justice of the Supreme Court of the United States, appointed by President Barack Obama in May 2009 and confirmed that August. She has the distinction of being its first Hispanic and Latina Justice.

Dissent

Justice Clarence Thomas, joined by Justice Anthony Kennedy, dissented. In his dissent, Thomas argued that the common law rule preventing an already-discharged jury to be re-empaneled should control the case. After surveying the history of jury's sequestration, Thomas argued that while the jury is no longer strictly sequestrated, such bright-line rule guarantees that jury will not be biased in any way and ensures that every trial is decided in a fair manner.

Clarence Thomas Associate Justice of the Supreme Court of the United States

Clarence Thomas is an American judge, lawyer, and government official who currently serves as an Associate Justice of the Supreme Court of the United States. He is currently the most senior associate justice on the Court following the retirement of Anthony Kennedy. Thomas succeeded Thurgood Marshall and is the second African American to serve on the Court. Among the current members of the Court he is the longest-serving justice, with a tenure of 27 years, 236 days as of June 16, 2019.

Anthony Kennedy American judge

Anthony McLeod Kennedy is an American lawyer and jurist who served as the 93rd Associate Justice of the Supreme Court of the United States from 1988 until his retirement in 2018. He was nominated to the court in 1987 by President Ronald Reagan, and sworn in on February 18, 1988. After the retirement of Sandra Day O'Connor in 2006, he was the swing vote on many of the Roberts Court's 5–4 decisions.

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References

  1. SCOTUSblog coverage
  2. 1 2 Dietz v. Bouldin, No. 15–458, 579 U.S. ___ (2016).
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