The Travelers Insurance Company v. Ray Ryan

416 F.2d 362, 1969 U.S. App. LEXIS 10867
CourtCourt of Appeals for the Fifth Circuit
DecidedSeptember 9, 1969
Docket26371
StatusPublished
Cited by27 cases

This text of 416 F.2d 362 (The Travelers Insurance Company v. Ray Ryan) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Travelers Insurance Company v. Ray Ryan, 416 F.2d 362, 1969 U.S. App. LEXIS 10867 (5th Cir. 1969).

Opinion

SIMPSON, Circuit Judge:

What are the permissible boundaries of fair judicial comment to the jury?

This recurring problem controls our review of this Texas Workmen’s Compensation Act Case. We determine that the trial judge, activated no doubt by the laudable motive of helping the jury reach what he considered the right verdict, markedly exceeded these limits by his comments. The result we view as a coerced verdict, requiring reversal.

The basic principle involved is clear; its application to individual cases is sometimes beclouded. 53 American Jurisprudence, Trials, Sec. 76, page 75, states it thus:

“In jury trials the trial judge should be cautious and circumspect in his language and conduct before the jury. He must be fair to both sides, and the extent to which he may go in comments and remarks during the trial is governed by the fundamental principle that nothing should be said or done by him which will prejudice the rights of the parties litigant. Especially should he refrain from any remarks that are calculated in any way to influence the minds of the jury or to prejudice a litigant.” (Emphasis supplied.)

In Starr v. United States, 1894, 153 U.S. 614, 14 S.Ct. 919, 38 L.Ed. 841, it is put:

“It is obvious that under any system of jury trials the influence of the trial judge on the jury is necessarily and properly of great weight, and that his lightest word or intimation is received with great deference, and may prove controlling.” 153 U.S. at p. 626, 14 S.Ct. at p. 923.

See further: United States v. Lanham, 5 Cir. 1969, 416 F.2d 1140, [Sept. 5, 1969]; Bollenbach v. United States, 1946, 326 U.S. 607, 612, 66 S.Ct. 402, 405, *364 90 L.Ed. 350, 354; Nunley v. Pettaway Oil Co., 6 Cir. 1965, 346 F.2d 95; Wabisky v. D. C. Transit System, Inc., 1963, 117 U.S.App.D.C. 115, 326 F.2d 658; Myers v. George, 8 Cir. 1959, 271 F.2d 168; Comer v. Smith’s Transfer Corp., 4 Cir. 1954, 212 F.2d 42; United States v. Link, 3 Cir. 1953, 202 F.2d 592. But cf. Doyle v. Union Pac. R.R. Co., 1893, 147 U.S. 413, 13 S.Ct. 333, 37 L.Ed. 223; United States v. Philadelphia and Reading R. R. Co., 1887, 123 U.S. 113, 8 S.Ct. 77, 31 L.Ed. 138; Kesley v. United States, 5 Cir. 1931, 47 F.2d 453.

It is precisely because of the important functions assigned to a trial judge, especially in a federal trial where these functions include the right to comment upon evidentiary matters, that the judge’s duty must be performed with strict neutrality and utmost impartiality. By reason of his role, quickly observed by jurors, the judge is a figure of overpowering influence, whose every change in facial expression is noted, and whose every word is received attentively and acted upon with alacrity and without question.

The instant case affords a clear illustration of the force of these observations. What we are saying is in no sense novel or original. The wine we pour is from old bottles indeed. We deal with maxims of the law, with truisms distilled in countless cases by unnumbered judicial forbears long since dust. But the principle is of continuing validity and vitality.

One further preliminary observation is in order. There is a difference between comment by the trial judge upon evidentiary matters, which if fair and unbiased is permissible, on the one hand, and comment by the judge upon the ultimate factual issues to be decided, on the other hand. The latter is not permitted. For instance, in a recent Sixth Circuit case, Nunley v. Pettaway Oil Co., supra, one of the special issues submitted was whether the plaintiff below, Nunley, was an invitee or a licensee on the Oil Company premises. When the jury indicated that they could not agree on this issue; the trial judge told them that while his view was advisory only, and not binding on the jury, he considered the evidence to show that Nunley was an invitee. This became the ultimate jury finding. The Sixth Circuit reversed:

“We recognize that the right of a District Judge to comment on the evidence is firmly established. See Quercia v. United States, 289 U.S. 466, 53 S.Ct. 698, 77 L.Ed. 1321 (1933), and the cases recited therein. We do not seek narrowly to confine this right when it is used to inform the jury as to problems which they must consider.
“We also recognize that the District Judge was motivated by a laudable desire to prevent a mistrial and that he clearly told the jury that it had the ultimate right to decide the issue concerned.
“Nevertheless, we believe that under the circumstances enumerated, the trial judge’s opinion on the licensee-invitee issue was an opinion on an ultimate fact question peculiarly for fury consideration and amounted to an instructed verdict as to defendant Pettaway Oil Company. * * *
“We believe the trial judge’s comment on the licensee-invitee issue went beyond the limits of judicial comment and invaded the ultimate fact-finding function of the fury.” Nunley v. Pettaway Oil Co., supra, 346 F.2d at page 99. (Emphasis added.)

As we develop below, the trial judge in our case gave the jury his views upon ultimate issues of fact, those of total versus partial and permanent versus temporary disability. This was an invasion of the ultimate fact-finding function of the jury, prejudicial to the rights of the appellant.

In the instant case the questioned conduct came when the jury attempted to return its verdict. The incident will be recounted in some detail largely by quotation from the record so as to present *365 the matter in context. As is usual in Texas trials, state or federal, the case had been submitted upon special interrogatories. 1 After about fifty minutes' of deliberation (4:25 P.M. to 5:15 P.M.) the jury returned to the courtroom and the foreman announced that they had reached a verdict. The verdict as read by the Clerk and the proceedings which then ensued are quoted in the margin. 2 *366

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Bluebook (online)
416 F.2d 362, 1969 U.S. App. LEXIS 10867, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-travelers-insurance-company-v-ray-ryan-ca5-1969.