Glover v. Crawford

District Court, D. New Hampshire·Decided May 24, 1996·No. CV-94-026-M·Published

Opinion

Glover v . Crawford CV-94-026-M 05/24/96 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Neil Glover, Plaintiff v. Civil Action N o . 94-26-M David Crawford, Defendant

O R D E R

Defendant, through the Office of the Attorney General, has renewed his trial motion for judgment as a matter of law on the dubious proposition that a jury's comment in an unsolicited note to the court during deliberations (related to an impending deadlock) should be construed as a special verdict entitling him to qualified immunity as a matter of law. The court disagrees. In any event, defendant waived his right (if any) to rely on the contents of the jury's note as a "special verdict" when defense counsel failed, prior to the jury's dismissal, to move the court to submit a special question designed to establish, with the requisite and customary indicia of clarity and reliability associated with verdicts, the jury "finding" that they now assert.

Discussion

An extended review of the facts of this case is not necessary. It is sufficient to note that plaintiff claims defendant, a New Hampshire State Trooper, arrested him for

disorderly conduct and public drunkenness during an annual motorcycle weekend event, without probable cause, and later

intervened to thwart his release on bail and to effect his further detention for several hours in "protective custody" (allegedly, because plaintiff was inebriated), again without probable cause. Plaintiff's version of the relevant facts differed markedly from defendant's version, and the jury could not resolve those discrepancies.

The facts pertinent to the pending motion are as follows.

On January 1 1 , 1996, after the jury had begun its deliberations, it submitted two written questions. After meeting with counsel to discuss an appropriate response, the court convened the parties and jury in the courtroom on the morning of January 1 2 . The court responded to the jury's questions on the record and the jurors returned to their deliberations. At that point, defense counsel moved for a mistrial on grounds that the jury was hopelessly confused. The motion was denied.

Later that afternoon, the jury sent another note to the court that read:

Judge as of 3:00 p.m., w e , the jury are unable to reach a unanimous decision based on the evidence. We would at this time like to be given further instructions.

The court reconvened the parties and jury in the courtroom and instructed the jury on its duty to deliberate and reach a unanimous verdict if the jurors could do so in good conscience. The jury was asked to return to the deliberation room to consider whether a unanimous verdict was attainable. Defense counsel again moved for a mistrial on grounds of jury deadlock. That motion was denied.

At the end of the day, the jury sent another note to the court (Question # 4 , document n o . 4 6 ) , which read:

W e , the jury believe Sergeant Crawford had probable cause to arrest Neil Glover for disorderly conduct + send him to station W .

We are divided on the charge of intoxication.

After discussion with counsel in chambers, the court responded to the note with a written question:

Do you believe you will be able to reach a unanimous verdict if you continue to deliberate for a reasonable time, o r , are you satisfied that further deliberation will not likely lead to unanimity?

Shortly thereafter, the jury responded by note, as follows:

W e , the jury have reached a deadlock. We do not feel that time will change our individual views.

Accordingly, the parties and jury were again reconvened in the courtroom, the court declared a mistrial, and dismissed the jurors with appreciation for their efforts. Defendant's counsel stood mute; they did not object to the mistrial (no doubt because they had twice requested that result earlier). Importantly, however, they did not request the court to submit a limited special verdict question to the jury based upon the comments in the note marked Jury Question # 4 . The case was subsequently scheduled for retrial.

At the final pretrial conference in chambers earlier this week, defense counsel pressed their previously rejected claim that defendant i s , as a matter of law, entitled to qualified immunity. Counsel's argument is based in large measure on the jury's note, in which it stated "We the jury believe Sergeant

Crawford had probable cause to arrest Neil Glover for disorderly conduct . . . ."1

There are obvious flaws in defense counsel's position.

First, the jury's note was not in response to any special question put to the jurors; it was unsolicited and related to the

status of their continuing deliberations at a particular point in the deliberative process. The note followed the court's request that the jurors return to consider whether a unanimous verdict might be achieved, and, in context, it simply informed the court that the jury had reached an impasse. While the jury should not have disclosed the nature of the impasse then prevailing or where they stood at that point in their deliberations, it cannot be said that the deliberative process was completed. Moreover, some

jurors may have "believed" (or perhaps even "agreed") that Crawford had probable cause to arrest plaintiff for disorderly

1 Even if the jury's informal note were treated as a special verdict in defendant's favor relative to plaintiff's initial arrest and referral for processing, that alone might not operate to relieve defendant of liability for what plaintiff alleges was defendant's subsequent intervention, at the processing center, for the purpose of thwarting plaintiff's impending release on bail on the disorderly conduct charge and his causing plaintiff, without any basis in fact, to be detained for several more hours in the county jail in "protective custody" status on an allegedly bogus charge of public intoxication.

conduct merely for the purpose of moving the jury's discussions from the initial arrest to defendant's potential liability for plaintiff's extended detention on the allegedly fabricated intoxication charge.

The note is also unreliable as a "finding" or a "special verdict" because: (1) it was not returned with the requisite formality in open court; (2) the jurors did not state that they unanimously agreed (as opposed to "believed") that, based on a preponderance of the evidence, defendant had probable cause to arrest plaintiff for disorderly conduct;2 (3) the court did not confirm (through the foreperson) that each juror concurred in the "verdict" or even that the jury actually intended the note to operate as a verdict, rather than simply an informative statement explaining their inability, at that particular moment, to return a verdict; and (4) plaintiff had no opportunity to have the

2 The jury's comment that "We believe Sergeant Crawford had probable cause . . . ." is a long way from, for example, "We unanimously agree by a preponderance of the evidence that . . . ." Even if we were to dispense with the customary formalities associated with the return of jury verdicts, which are, of course, designed to insure clarity and reliability, in my judgment the jury's statement here was at best tentative, not final, and not made under any circumstances from which the requisite degree of clarity and certitude necessary for a proper civil verdict could be inferred.

individual jurors polled in open court to verify that each juror understood and intended that the note would constitute a final

jury determination on the probable cause issue in compliance with the court's charge.3

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