ART+COM Innovationpool GmbH v. Google Inc., 1-14-cv-00217 (DED September 9, 2016, Order) (Dyk, CJ)
Friday, September 16, 2016
Cursory Jury Deliberation Does Not Justify New Trial
The court denied plaintiff's motion for new trial because of the jury's "cursory" deliberations after a five-day trial. "[Plaintiff] argues that the jury deliberations took only 45 minutes, and '[t]hese cursory 'deliberations' yielded a verdict counter to the great weight of the evidence.' However, '[b]rief jury deliberation is not, in itself, sufficient basis to support a new trial motion. [The] Fourth Circuit once upheld the trial court's denial of a new trial motion where the jury had deliberated only four minutes. . . .' Here, the jury was extremely attentive throughout the trial, as evidenced by the questions it submitted to be asked of witnesses, and appeared to take the matter very seriously."