South-Western Legal Studies in Business

Trial Court Must Provide Justification for Granting New Trial

California high court held that it was improper for a trial judge to simply order a new trial when the losing party requested one, without providing a justification for the order based on evidence of the grounds for a new trial, in this case, jury misconduct.

Topic Court Procedure
Key Words

Appeal; Juror Misconduct; Independent Review

C A S E   S U M M A R Y

The pro football team the Oakland Raiders is a member of the National Football League (NFL). The Raiders played in Los Angeles from 1982 to 1995 in an old stadium. The Raiders negotiated with a group about building a new stadium in the LA area. The NFL wanted another team in the LA area and the deal collapsed. The Raiders moved to Oakland and sued the NFL for damages for profits it could have earned had it been in a new stadium in LA. The jury deliberated for 15 days and returned a 9-3 verdict for the NFL. The Raiders moved for a new trial on the grounds of juror misconduct. They asserted that one juror was biased against the Raiders and hid that fact during voir dire. Another juror, an attorney, dominated jury deliberations, and infected the deliberations. The Raiders submitted declaration from five jurors in support of their contention. Seven other jurors disagreed. The trial court granted a new trial. The NFL appealed. The appeals court held for the NFL because the trial judge failed to provide a statement of reasons for granting a new trial based on juror misconduct. The Raiders appealed.


Affirmed. A trial court may grant a new trial because of jury misconduct, but a statement of the grounds for a new trial must be provided. The trial court may not order it without giving reasons that refer to the evidence for the decision. Since the trial court failed to provide justification for its decision, on appeal, the moving party, the Raiders, must provide grounds to the appeals court, which provides an independent review of the matter.


Oakland Raiders v. National Football League, 161 P.3d 151 (Sup. Ct., Calif., 2007)

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