Dietz v. Bouldin, 136 S. Ct. 1885

Dietz sued Bouldin for negligence after a T‑boning car crash; Bouldin admitted liability and stipulated that Dietz’s medical expenses were $10,136.
The jury asked during deliberations whether the $10,136 had been paid and by whom; the judge (with parties’ consent) told the jury the information was irrelevant.
The jury returned a verdict for Dietz but awarded $0 in damages; the judge discharged the jury, then quickly realized a $0 award was legally inconsistent with the stipulation.
Minutes after discharge, the judge recalled the jurors (most stayed in the courthouse), questioned them as a group, reinstructed them, and ordered further deliberations; the reassembled jury awarded $15,000.
Dietz objected to recall and sought a new trial; the Ninth Circuit affirmed, and the Supreme Court considered whether a district court may rescind a discharge and recall a civil jury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a federal district court may rescind a discharge order and recall a civil jury to correct an error in the verdict	Dietz argued recalling a discharged jury is categorically barred (common‑law rule) or at least improper once jurors are effectively released; recall risks undetectable prejudice	Respondent and the court below argued the district court has inherent power to recall a recently discharged jury in limited circumstances to correct an identifiable error and avoid a new trial	The Court held district courts have a limited inherent power to rescind a discharge and recall a civil jury, but must exercise it cautiously using a prejudice‑focused, multi‑factor inquiry

Link v. Wabash R. Co., 370 U.S. 626 (recognition of courts’ inherent power to manage affairs for orderly disposition)
Degen v. United States, 517 U.S. 820 (inherent powers must be reasonable and not contradict rules/statutes)
Marconi Wireless Telegraph Co. of America v. United States, 320 U.S. 1 (district courts can modify or rescind orders before final judgment)
Landis v. North American Co., 299 U.S. 248 (inherent power to manage docket for efficient resolution)
Chambers v. NASCO, Inc., 501 U.S. 32 (inherent powers are potent and must be exercised with restraint)
Remmer v. United States, 347 U.S. 227 (external contact with jurors is presumptively prejudicial)
Kotteakos v. United States, 328 U.S. 750 (modern harmless‑error approach replacing rigid common‑law remedies)
Carlisle v. United States, 517 U.S. 416 (limits on recognizing new inherent powers when inconsistent with established practice)