Citing Importance of Jury Service, Court Denies Motion to Vacate Judgment Following Jury Verdict

Let’s face it:  jury service can be a major inconvenience. But, like paying taxes, it’s not voluntary.  The recent words of a federal judge, however, may be just inspirational enough to make performing one’s civic duty more bearable.

In Clark v. Castro, the Southern District of New York explained why it refused to vacate a judgment following a jury verdict in plaintiff’s favor.

Plaintiff sued under 42 U.S.C. § 1983, alleging false arrest and denial of a right to a fair trial.  The jury ruled in plaintiff’s favor on the fair trial claim, but in defendant’s favor on the false arrest claim (having found that probable cause existed for plaintiff’s arrest).

After judgment was entered, the parties reached a settlement under which plaintiff would receive the verdict amount ($37,000) and plaintiff’s counsel would accept a reduced fee. The agreement, however, was contingent on vacating the judgment. Plaintiff sought this relief under Federal Rule of Civil Procedure 60.

The court denied the motion, finding that the “exceptional circumstances” required were not present.  In particular, the fact that the settlement agreement provided for vacatur was not enough.

In addressing the parties’ argument that the the judgment on the jury’s verdict can be disregarded because the verdict has “minimal precedential value”, the court stated:

The parties’ conception of the public interests implicated by vacatur is too narrowly drawn. I agree that the jury verdict has limited precedential value because it only decided the particular facts of this action. Nonetheless, the fact that a judgment is not premised upon a legal opinion does not strip it of its social value. … Indeed, a judgment, entered on the basis of a jury verdict, reaffirms the Constitutionally-recognized social value of trial by jury in civil actions [as embodied in the Seventh Amendment to the U.S. Constitution].

Granting the motion to vacate would unjustly trivialize the time, attention and effort expended by the eight citizens who served as jurors in this case. The product of their deliberations would, officially, be wiped away, and the members of the jury might justifiably ask themselves “Why did I bother to serve?” or “Why should I bother to serve the next time I’m called when my decision was discarded in Ms. Clarke’s case?” Vacatur would essentially cast the jury as a “shadow jury” responsible only for issuing a de facto advisory opinion on an appropriate settlement figure. Moreover, like judicial determinations, jury verdicts and the judgments entered upon them are not the private property of the litigants. … Given the central role juries play in our common law system of justice and in ensuring that our government really is a government “by the people,” I am loathe to take any action that depreciates the verdict reached by eight honest and conscientious citizens in this case.

In fact, in discussing the importance of the right to a jury trial in our system, the court noted that the deprivation of that right was identified as one of the “long Train of Abuses and Usurpations” that gave rise to the Declaration of Independence.

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