Court Power & Discretion

Listen to this article

Supreme Court

Case Name: Dietz v. Bouldin

Case No.: 15-458

Focus: Court Power & Discretion

A federal district court has a limited inherent power to rescind a jury discharge order and recall a jury in a civil case for further deliberations after identifying an error in the jury’s verdict.

“The inherent powers that district courts possess “to manage their own affairs so as to achieve the orderly and expeditious disposition of cases,” Link v. Wabash R. Co., 370 U. S. 626, 630–631, have certain limits. The exercise of an inherent power must be a “reasonable response to the problems and needs” confronting the court’s fair administration of justice and cannot be contrary to any express grant of, or limitation on, the district court’s power contained in a rule or statute. Degen v. United States, 517 U. S. 820, 823–824. These two principles support the conclusion here. First, rescinding a discharge order and recalling the jury can be a reasonable response to correcting an error in the jury’s verdict in certain circumstances, and is similar in operation to a district court’s express power under Federal Rule of Civil Procedure 51(b)(3) to give the jury a curative instruction and order them to continue deliberating to correct an error in the verdict before discharge. Other inherent powers possessed by district courts, e.g., a district court’s inherent power to modify or rescind its orders before final judgment in a civil case, see Marconi Wireless Telegraph Co. of America v. United States, 320 U. S. 1, 47–48, or to manage its docket and courtroom with a view toward the efficient and expedient resolution of cases, see Landis v. North American Co., 299 U. S. 248, 254, also support this conclusion. Second, rescinding a discharge order to recall a jury does not violate any other rule or statute. No implicit limitation in Rule 51(b)(3) prohibits a court from rescinding its discharge order and reassembling the jury. Nor are such limits imposed by other rules dealing with postverdict remedies. See, e.g., Fed. Rules Civ. Proc. 50(b), 59(a)(1)(A). “

Affirmed

Concurring:

Dissenting: THOMAS, KENNEDY

Full Text

Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.