HAROLD CONNOR MINNIS AND DADE COUNTY, A POLITICAL SUBDIVISION OF THE STATE OF FLORIDA, APPELLANTS,
v.
MINNIE JACKSON, APPELLEE
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Appellants Harold Minnis and Dade County appeal a $45,000 jury verdict in a personal injury case, arguing the trial was tainted by a juror's false answers during voir dire. The Florida appellate court reversed, holding that a juror's dishonest answers to material questions on voir dire constitute grounds for a new trial regardless of whether the juror's bias actually affected the verdict.
The court held that a juror's failure to honestly answer material questions on voir dire constitutes bad faith requiring a new trial, regardless of whether the juror's bias actually influenced the verdict. The right to an impartial jury is destroyed when the right to make an intelligent judgment about whether to challenge a juror is lost or impaired through false voir dire answers.
[1] A juror's failure to honestly answer material questions during voir dire constitutes bad faith requiring disqualification.
[2] The right to a fair trial by an impartial jury is destroyed when the right to intelligently challenge a juror is impaired.
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Join FLexlaw to unlock all legal intelligence“the failure of a juror to honestly answer material questions propounded to him on voir dire examination constitutes bad faith requiring his disqualification from serving on the jury in the case”
Establishes the core legal rule that dishonest voir dire answers are grounds for disqualification
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Join FLexlaw to unlock all legal intelligenceMinnie Jackson was injured as a passenger on a Dade County MTA bus and sued for damages. The county admitted liability, and the jury returned a $45,00…
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PER CURIAM.
Defendants Harold Minnis and Dade County appeal a $45,000 final judgment for the plaintiff entered pursuant to a jury verdict.
Plaintiff, Minnie Jackson, was injured while riding as a passenger on a County MTA bus. She filed the instant suit for damages against defendants Dade County and the bus driver, Harold Minnis, and the County admitted liability. A trial was held on the issue of damages and the jury returned a verdict for $45,000. After entry of final judgment, defense counsel discovered that the jury foreman, Daniel Medvin, had given false answers during voir dire examination, i. e. upon being asked whether any members of his family had been in an accident where they had been injured, Medvin replied in the negative when, in fact, his daughter had been injured in a county bus a year before. Although no legal action had been instituted, a claim had been filed with the county. Defense counsel moved for a new trial on this ground. A rule to show cause was issued and a hearing was held at which the jurors were questioned by counsel and the trial judge. Medvin denied that his fairness as a juror had been affected or that he had played an active role in the jury discussions leading to a verdict. The other remaining jurors were questioned and the fact was brought out that Medvin • recommended that the verdict be high enough to allow the plaintiff to pay her attorney. The trial judge denied the motion for new trial and this appeal ensued. We reverse.
The well established rule is that the failure of a juror to honestly answer material questions propounded to him on voir dire examination constitutes bad faith requiring his disqualification from serving on the jury in the case. Seay v. State, 139 Fla. 433, 190 So. 702 (1939). Further, the right of counsel to challenge a juror for cause or peremptorily being indispensible to the successful operation of our jury system, the right of fair trial by an impartial jury is destroyed when the right to make an intelligent judgment as to whether a juror should be challenged is lost or unduly impaired. When this occurs, the verdict should be set aside and a new trial granted. Ellison v. Cribb, Fla.App.1972, 271 So. 2d 174. For the question is not whether an improperly established tribunal acted fairly, but whether a proper tribunal was established. Skiles v. Ryder Truck Lines, Inc., Fla.App.1972, 267 So. 2d 379.
The final judgment is reversed and the cause remanded to the trial court for a new trial on the issue of damages.
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Citator
Cited By (13 total)
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E. AIR Lines, Inc. v. Gellert, 438 So. 2d 923 (Fla. 3d DCA 1983)…ave a fair opportunity to make an intelligent judgment as to the exercise of the peremptory challenges guaranteed to him by law, see Loftin v. Wilson, 67 So. 2d 185 (Fla.1953); Ritter v. Jimenez, 343 So. 2d 659 (Fla. 3d DCA 1977); Minnis v. Jackson, 330 So. 2d 847 (Fla. 3d DCA 1976); Saborit v. Deliford, 312 So. 2d 795 (Fla. 3d DCA 1975), cert. denied, 327 So. 2d 32 (Fla.1976); Ellison v. Cribb, 271 So. 2d 174 (Fla. 1st DCA 1972), cert. denied, 272 So. 2d 160 (Fla.1973); Barker v. Randolph, 239 So. 2d 110. E…
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Bernal v. Donald H. Lipp, D.P.M. & Donald H. Lipp, D.P.M., P.A., 580 So. 2d 315 (Fla. 3d DCA 1991)…-79 (Fla. 4th DCA 1984). As to the second prong of the test, the information was concealed from counsel, as a result of which counsel lost “the right to make an intelligent judgment as to whether a juror should be challenged....” Minnis v. Jackson, 330 So. 2d 847, 848 (Fla. 3d DCA 1976). Since the information was squarely asked for and was not provided, this branch of the test is satisfied. See Skiles v. Ryder Truck Lines, Inc., 267 So. 2d 379, 382 (Fla. 2d DCA 1972), cert. denied, 275 So. 2d 253 (Fla.1973).…
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Jefferson Mitchell v. State, 458 So. 2d 819 (Fla. 1st DCA 1984)…se of a peremptory challenge. The right of peremptory challenge implies the right to make an intelligent judgment as to whether a juror should be excused. Counsel have the right to truthful information in making that judgment. See Minnis v. Jackson, 330 So. 2d 847 (Fla. 3rd DCA 1976); Loftin v. Wilson, 67 So. 2d 185 (Fla.1953); Skiles v. Ryder Truck Lines, Inc., 267 So. 2d 379 (Fla. 2nd DCA 1972). The state argues that the defendant should be denied relief because the juror’s untruthful response was not inte…
Previewing 3 of 13 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Decker v. State, 267 So. 2d 379 (Fla. 2d DCA 1972)
- Frederick v. Frederick, 267 So. 2d 379 (Fla. 4th DCA 1971)
- Seay v. State, 139 Fla. 433 (Fla. 1939)
- Ellison v. Gurney A. Cribb, Jr., 271 So. 2d 174 (Fla. 1st DCA 1972)