Legal Memorandum: Irreconcilably Inconsistent Jury Verdicts

Issue: Can irreconcilably inconsistent jury verdicts in a civil case be tolerated?

Area of Law: Litigation & Procedure
Keywords: Irreconcilably inconsistent jury verdicts; Tolerance
Jurisdiction: Maryland
Cited Cases: 836 A.2d 627; 166 Md. App. 67; 378 Md. 461; 405 Md. 10; 949 A.2d 619
Cited Statutes: None
Date: 08/01/2008

As observed in Patras v. Syphax, the “Court of Appeals has held that ‘irreconcilably inconsistent jury verdicts’ in a civil case ‘cannot stand.'”  166 Md. App. 67, 75 887 A.2d 84 (2005) (quoting S. Mgmt. Corp. v. Taha, 378 Md. 461, 487-88, 836 A.2d 627 (2003)).  See Price v. State, 405 Md. 10, 949 A.2d 619 (2008) (concluding that inconsistent verdicts cannot stand in criminal cases any more than in civil cases).  The Court of Appeals recently explained that when the trial court fails to exercise its broad discretion by allowing a judgment based on irreconcilably inconsistent jury findings to stand, the trial court errs as a matter of law and the judgment must be vacated.  See Taha, 378 Md. at 495, 836 A.2d at 647.

In Patras, the jury found negligence and awarded zero total damages, two findings that the Court of Special Appeals held were not inconsistent.  Id., 166 Md. App. at 75, 887 A.2d at 88.  In Patras, “the jury could have concluded that [the defendant’s] negligence caused an almost negligible impact with [the plaintiff’s] vehicle” and, at the same time and “in conformity with the court’s instructions, believed that Patras had no legitimate medical expenses resulting from the accident.”  Id. at 76, 887 A.2d at 89.  The jury could have found that the plaintiff “failed to meet his burden of proving the amount of money that would compensate […]

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