Faria v. Harleysville Worcester Insurance Co.
852 F.3d 87
| 1st Cir. | 2017Background
- Brian and Melissa Faria sued their insurer, Harleysville, over denial of uninsured-motorist coverage; case went to jury trial in Rhode Island federal court.
- Prospective juror John R. Rieger completed a juror qualification form disclosing a prior felony conviction and that his "voting rights" were restored, but omitted full details, did not sign the form, and later served on the jury; Rieger announced the verdict for Harleysville.
- After verdict, the Farias learned Rieger had been convicted of assault with a dangerous weapon and was on probation/suspended sentence when he served, making him statutorily ineligible under 28 U.S.C. § 1865(b)(5).
- The Farias moved for a new trial; the district court found Rieger was ineligible but concluded the Farias may have waived procedural challenges and, on the merits, found no dishonest answers or resulting prejudice and denied a new trial.
- The Farias appealed; the First Circuit reviewed for abuse of discretion, evaluated waiver arguments, applicability of McDonough, and whether any juror nondisclosure demonstrated bias that deprived the Farias of a fair trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Waiver under JSSA procedures for challenging jurors | Faria: They could not be expected to know about access to questionnaires and did not waive challenge | Harleysville: Farias failed to move for forms or timely challenge; JSSA procedures required raising issue before/shortly after voir dire | Court assumed possible waiver but declined to decide on that ground and resolved on merits instead |
| Applicability of McDonough test (juror dishonesty) to qualification forms | Faria: McDonough applies equally to qualification forms and voir dire; Rieger was dishonest on form and by silence at voir dire | Harleysville: McDonough governs voir dire dishonesty only; qualification forms are clerk gate-keeping; Rieger's form disclosed felon status | Court applied McDonough framework but found Farias did not meet its requirements |
| Whether Rieger answered dishonestly / required hearing | Faria: Rieger intentionally concealed conviction and restoration status; district court should have held evidentiary hearing | Harleysville: Rieger disclosed enough to reveal felony; his answer that "voting rights" restored was reasonable; Farias waived right to a hearing | Court found district court did not clearly err: answers were reasonably truthful/mistaken and no hearing was required because Farias declined one |
| Prejudice / bias showing necessary for new trial | Faria: Statutory ineligibility alone warranted new trial under McDonough once dishonesty shown | Harleysville: Statutory ineligibility does not equal bias; must show actual prejudice affecting fairness | Court held Farias failed to show juror bias or demonstrable prejudice; denial of new trial affirmed |
Key Cases Cited
- McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (establishes two-prong test for juror dishonesty and need to show for-cause basis)
- United States v. Uribe, 890 F.2d 554 (1st Cir. 1989) (procedural requirements under JSSA must be invoked; felon juror issues and waiver)
- Sampson v. United States, 724 F.3d 150 (1st Cir. 2013) (standard on juror-bias claims and deference to district court credibility findings)
- Crowley v. L.L. Bean, Inc., 303 F.3d 387 (1st Cir. 2002) (speculation about juror bias insufficient for new trial)
- DeBurgo v. St. Amand, 587 F.3d 61 (1st Cir. 2009) (burden on party seeking new trial to show bias by preponderance)
- Caron v. United States, 524 U.S. 308 (civil rights restoration includes jury service and holding office)