词源与由来: From Anglo-Norman French 'verdit,' from Latin 'vere dictum' meaning 'truly said' or 'a true declaration,' reflecting the jury's duty to speak the truth of the matter.
After deliberations conclude, the jury returns to the courtroom and the foreperson announces the verdict. The judge may poll each juror individually to confirm their agreement with the verdict as announced. In civil cases, the court may submit special verdict forms asking the jury to answer specific factual questions, or general verdicts with interrogatories. After a guilty verdict in criminal cases, the judge will typically set a sentencing date. Either party may move for judgment notwithstanding the verdict (JNOV) or a new trial if they believe the verdict is unsupported by the evidence.
Judge: "Members of the jury, have you reached a unanimous verdict?"
Foreperson: "We have, Your Honor. On Count One, we find the defendant guilty of wire fraud."
Attorney: "Your Honor, we request that the jury be polled individually."
Students often confuse a not guilty verdict with a finding of innocence. A not guilty verdict means the prosecution failed to meet its burden of proof beyond a reasonable doubt; it does not affirmatively establish that the defendant is innocent.
United States v. Powell, 469 U.S. 57 (1984)
Held that inconsistent verdicts in criminal cases do not require reversal, recognizing jury lenity and compromise as permissible.
Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 133 (2000)
Clarified the standard for JMOL, holding courts must review all evidence in the light most favorable to the non-moving party.
Apprendi v. New Jersey, 530 U.S. 466 (2000)
Held that any fact increasing the penalty beyond the statutory maximum must be submitted to a jury, expanding the scope of the jury's verdict role.
| General Verdict | Special Verdict |
|---|---|
| Single finding for plaintiff or defendant | Jury answers specific factual questions |
| Jury applies law to facts (as instructed) | Judge applies law to jury's factual findings |
| Less transparent reasoning | Reveals the jury's factual determinations |
| Harder to challenge on appeal | Easier to identify errors in reasoning |
| Traditional and most common form | Used in complex cases under Rule 49(a) |
What is the difference between a general verdict and a special verdict?
A general verdict is the jury's overall finding for plaintiff or defendant. A special verdict under Rule 49(a) requires the jury to answer specific factual questions with the judge applying the law to those findings.
Can a jury verdict be overturned by the judge?
Yes, through judgment as a matter of law (JMOL) under Rule 50 if no reasonable jury could have reached the verdict, or through a new trial under Rule 59 if against the great weight of evidence.
What happens when a jury returns an inconsistent verdict?
In civil cases, a court may order a new trial. In criminal cases under United States v. Powell, inconsistent verdicts across multiple counts are generally allowed as reflecting jury lenity.
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