## Facts

- Billy Greenwood, a Kansas juvenile, suffered severe foot injuries involving the rotating blades of a riding lawnmower manufactured by McDonough Power Equipment, Inc.
- Greenwood and his parents sued McDonough in federal district court for damages.
- During voir dire, the judge asked prospective jurors whether they or close family members had suffered injuries resulting in disability or prolonged pain or suffering.
- One seated juror did not respond, despite her son’s prior injury (a broken leg caused by an exploding tire).
- After a three-week trial, the jury returned a defense verdict for McDonough.

## Issues

1. Whether a civil verdict must be set aside when a juror gives an inaccurate or incomplete answer to a material voir dire question that could have affected peremptory challenges, absent a showing the nondisclosure resulted in an impartial jury.

## Decision

- The Supreme Court reversed the court of appeals and reinstated the judgment for McDonough.
- The Court held that an inaccurate voir dire answer does not, by itself, justify a new trial.
- A new trial is warranted only if (1) the juror failed to answer honestly a material question on voir dire, and (2) a correct response would have provided a valid basis for a challenge for cause.
- On the record presented, respondents did not show dishonest nondisclosure or that the undisclosed information would have supported a challenge for cause.

## Legal Principles

- A verdict may be attacked for juror voir dire inaccuracy only if: (1) the juror did not answer honestly a material question, and (2) a truthful answer would have supported a for-cause challenge.
- The core protection is the right to an impartial jury; the legal system does not require error-free voir dire.
- Harmless-error principles govern: courts should disregard errors that do not affect substantial rights under Fed. R. Civ. P. 61 and 28 U.S.C. § 2111.
- Impairment of peremptory challenges, without a showing of disqualifying bias or other grounds for a for-cause challenge, is insufficient to overturn a civil verdict.

## Conclusion

A civil judgment is not set aside merely because a juror gave an inaccurate or incomplete voir dire response; the moving party must show dishonest nondisclosure of a material fact and that a truthful answer would have justified removing the juror for cause, consistent with harmless-error limits on post-verdict relief.


McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (1984)