Jitnan v. Oliver

Appellant Joonsong Jitnan and his wife instituted a personal injury action against Ryan Oliver for injuries arising out of an automobile accident. During the voir dire, appellants exercised a challenge for cause to a prospective juror. The district court denied the challenge for cause, and appellants subsequently exercised a peremptory challenge on the prospective juror. After the trial, Jitnan appealed, arguing (1) the district court abused its discretion denying the challenge for cause to the prospective juror, and (2) the court's erroneous denial of the challenge for cause required reversal because in using a peremptory challenge to cure the district court's error, appellants lost one of their peremptory challenges, which was prejudicial. The Supreme Court affirmed, holding (1) when a prospective juror expresses a potentially disqualifying bias or prejudice and is inconsistent in his or her responses regarding that preconception upon further inquiry, the district court must set forth the reasons for its grant or denial of the challenge for cause; and (2) although the district court in this case failed to set forth its reasons for denying the challenge for cause, there was no prejudicial error requiring reversal because the jury that decided appellants' case was fair and impartial.