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."

ART+COM Innovationpool GmbH v. Google Inc., 1-14-cv-00217 (DED September 9, 2016, Order) (Dyk, CJ)