Legal Memorandum: Effect of an Ambiguous Special Verdict Interrogatory

Issue: Under Minnesota law, what is the effect of an ambiguous special verdict interrogatory on the judgment?

Area of Law: Litigation & Procedure
Keywords: Special verdict interrogatory; Ambiguous; Judgment
Jurisdiction: Minnesota
Cited Cases: 16 N.W. 425
Cited Statutes: None
Date: 02/01/2014

It has long been recognized in Minnesota that a judgment is inappropriate, and a new trial necessary, where the jury’s special verdict interrogatory answers are ambiguous.  Pint v. Bauer, 31 Minn. 4, 16 N.W. 425 (1883).  Where the ambiguity of the question makes it unclear which of multiple defendants the jury intends to designate, the jury’s answer cannot form the proper basis for a judgment.  See Fidelity and Guar. Ins. Underwriters, Inc. v. Rodriguez, 141 Fed. Appx. 11, 13 (2d Cir. 2005). 


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