McDonough Power Equipment, Inc. v. Greenwood

McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984), was a case decided by the Supreme Court of the United States that established a standard for challenging a verdict based on inaccurate answers given by prospective jurors during voir dire.[1]

McDonough Power Equipment v. Greenwood
Argued November 28, 1983
Decided January 18, 1984
Full case nameMcDonough Power Equipment, Inc. v. Greenwood, et al.
Citations464 U.S. 548 (more)
104 S. Ct. 845; 78 L. Ed. 2d 663
Case history
PriorGreenwood et al. v. McDonough Power Equipment, Inc., 687 F.2d 338 (10th Cir. 1982).
Holding
A juror's failure to respond to question on voir dire did not require new trial absent a showing of denial of right to impartial jury.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
John P. Stevens · Sandra Day O'Connor
Case opinions
MajorityRehnquist, joined by Burger, White, Blackmun, Powell, Stevens, O'Connor
ConcurrenceBlackmun, joined by Stevens, O'Connor
ConcurrenceBrennan, joined by Marshall
Laws applied
Rule 61 of the Federal Rules of Civil Procedure, 28 U.S.C. § 2111

Background

Bill Greenwood was a juvenile in Kansas whose feet were severed on a riding lawnmower manufactured by McDonough. Before the three-week trials, one of the jurors failed to disclose that her son had sustained a broken leg as a result of an exploding tire. Although McDonough would likely have used a peremptory challenge if they had known the background, there was no direct conflict of interest and the rest of the jurors quickly ruled against the manufacturer in deliberations.

Decision

The standard adopted by the Court in McDonough was that a verdict could be challenged because of inaccurate answers given during voir dire only if the juror failed to honestly answer a question and an honest answer would have provided a valid basis for a challenge for cause.[2]

See also

References
  1. Yeazell, S.C. Civil Procedure, Seventh Edition. Aspen Publishers, New York, NY: 2008, p. 594
  2. Yeazell, p. 594
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