Merritt v. Cogley

Summary

The United States District Court for the Southern District of California denied Defendant Jonathan Cogley’s ex parte motion for leave to interview jurors after a verdict for Plaintiff Ian Merritt. The court held that Cogley had shown neither juror misconduct nor that extraneous prejudicial information reached the jury, and that his asserted basis was speculative. The court emphasized protections against postverdict inquiry into jury deliberations and the presumption that jurors follow court instructions.

Holdings

1. A party is not entitled to postverdict interrogation of jurors absent a showing of juror misconduct or that extraneous prejudicial information reached the jury; speculative allegations are insufficient.
2. The jury is presumed to follow instructions not to consider a party's wealth and not to conduct independent research absent a sufficient showing to overcome that presumption.

Questions Presented

1. Whether Defendant established a sufficient basis for postverdict juror interviews by showing possible juror misconduct or exposure to extraneous prejudicial information.
2. Whether speculation that jurors may have researched Defendant's wealth, based on the evidence and the size of the verdict, justified ex parte juror interviews.

Disposition

other