Juror Misconduct and the Use of Juror Affidavits: Insights from Keyes v. Amundson

Juror Misconduct and the Use of Juror Affidavits: Insights from Keyes v. Amundson

Introduction

Bradley Keyes appealed the judgment in Keyes v. Amundson, a case arising from a motorcycle-automobile accident in Williston, North Dakota. The incident involved multiple parties, including Susan Amundson, Robert Amundson, Craig Stoner, G J Hotshot Service, Inc., and Getter Trucking, Inc. The crux of Keyes' appeal centered on allegations of juror misconduct that potentially prejudiced the trial's outcome.

Summary of the Judgment

The North Dakota Supreme Court vacated the original judgment, reversed the order denying Keyes' motion for a new trial, and remanded the case for a new trial. The primary issues addressed were the unauthorized separation of jurors over the weekend and subsequent juror actions that led to the acquisition of extraneous prejudicial information. The court concluded that these procedural missteps warranted a new trial due to the reasonable possibility that such misconduct could have influenced the verdict.

Analysis

Precedents Cited

The judgment extensively references both statutory provisions and prior case law to establish the framework for evaluating juror misconduct:

  • Comparative Negligence Statute § 9-10-07, N.D.C.C.: Governs the apportionment of negligence among parties.
  • STATE v. BERGERON, 340 N.W.2d 51 (N.D. 1983):
  • KERZMANN v. ROHWEDER, 321 N.W.2d 84 (N.D. 1982):
  • GRENZ v. WERRE, 129 N.W.2d 681 (N.D. 1964):
  • James Turner Sons v. Great Northern Railway Co., 67 N.D. 347 (1937):
  • Federal Rules of Evidence, Rule 59(b)(2) and Rule 606(b).

These precedents collectively shaped the court's interpretation of juror conduct rules, particularly concerning the admissibility and impact of juror affidavits.

Legal Reasoning

The court meticulously dissected the application of Rules 59(b)(2) and 606(b) to determine the admissibility and relevance of juror affidavits in cases of misconduct beyond chance verdicts.

  • Juror Separation: The trial court erroneously permitted the jurors to be dismissed over the weekend, contrary to § 28-14-18, N.D.C.C., which restricts temporary dismissals to an eight-hour period. Additionally, the court failed to admonish jurors against discussing the case during dismissal.
  • Juror Misconduct: Post-dismissal, jurors engaged in unauthorized investigations of the accident scene, leading to the acquisition and dissemination of prejudicial information not present during the trial.
  • Affidavit Admissibility: The trial court incorrectly applied Rule 59(b)(2), limiting the use of juror affidavits to cases where the verdict was arrived at by chance. The Supreme Court clarified that Rule 606(b) permits affidavits to address broader misconduct, including extraneous information and external influences.
  • Prejudicial Impact: Applying the standard from federal cases, the court assessed whether there was a reasonable possibility that the extraneous information could have affected the verdict, finding sufficient grounds to warrant a new trial.

Impact

This judgment has significant implications for future cases involving juror misconduct:

  • Clarification of Rules: The court provided a nuanced interpretation of Rules 59(b)(2) and 606(b), ensuring that juror affidavits addressing a range of misconduct are admissible, thereby broadening the scope for challenging verdicts based on juror behavior.
  • Precedent for New Trials: Establishing that a reasonable possibility of prejudicial impact is sufficient to grant a new trial sets a lower threshold for appellate courts to intervene in cases of juror misconduct.
  • Jury Management: Emphasizes the necessity for courts to adhere strictly to statutory guidelines regarding juror conduct and separation to prevent opportunities for misconduct.

Complex Concepts Simplified

Comparative Negligence

This legal doctrine involves allocating fault among parties involved in an accident. In this case, negligence was apportioned among Keyes, Amundson, and Stoner, leading to the dismissal of Keyes' claim under the comparative negligence statute because his fault negated his recovery.

Juror Affidavits

Affidavits submitted by jurors can be used to demonstrate misconduct, such as obtaining prejudicial information outside the courtroom. The court differentiated between using affidavits to show a verdict was by chance versus other forms of misconduct.

Rules 59(b)(2) and 606(b)

Rule 59(b)(2): Provides grounds for a new trial, including juror misconduct and verdicts by chance.

Rule 606(b): Governs the testimony of jurors regarding their deliberations, prohibiting disclosure of internal deliberations but allowing testimony on external influences and prejudicial information.

Conclusion

The Keyes v. Amundson decision underscores the importance of maintaining strict adherence to juror conduct statutes to uphold the integrity of verdicts. By clarifying the admissibility of juror affidavits beyond mere chance verdicts, the court reinforced mechanisms to address and rectify instances of juror misconduct effectively. This ensures that the pursuit of justice remains uncompromised by procedural oversights or unethical juror behavior.

Case Details

Year: 1983
Court: Supreme Court of North Dakota.

Judge(s)

VANDE WALLE, Justice, concurring specially.

Attorney(S)

Greenwood, Greenwood Greenwood, Dickinson, for plaintiff and appellant; argued by Dann Greenwood, Dickinson. Bjella, Neff, Rathert, Wahl Eiken, Williston, for defendants and appellees Amundsons; argued by Paul W. Jacobson, Williston. Letnes, Marshall, Fiedler Clapp, Grand Forks, for defendants and appellees Stoner and G J Hotshot Service, Inc.; argued by Jay H. Fiedler, Grand Forks. McIntee Whisenand, Williston, for defendant and appellee Getter Trucking, Inc.; argued by Frederick E. Whisenand, Williston.

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