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A.E. Staley Mfg Co v. Class
Citation: Not availableDocket: 04-8004
Court: Court of Appeals for the Seventh Circuit; March 17, 2004; Federal Appellate Court
Original Court Document: View Document
In the case before the United States Court of Appeals for the Seventh Circuit, antitrust class action litigation is brought against Archer Daniels Midland Company (ADM) and other defendants for alleged price-fixing of high fructose corn syrup, violating the Sherman Act. A previous ruling had reversed a summary judgment for the defendants, leading to preparations for trial. A key issue arose regarding the admissibility of damaging evidence against ADM, which would not be applicable to the other defendants. The presiding judge proposed using two juries: one for ADM's liability and another for the other defendants, to prevent potential bias. However, the judge determined that this approach lacked explicit authorization under existing rules and certified the issue for immediate appeal under 28 U.S.C. 1292(b). The appeal highlights that only Staley remains as an appellant seeking separate juries, opposed by ADM and the plaintiffs. It was agreed that the criteria for severing claims under Fed. R. Civ. P. 21 were not met, and while no specific rule allows for separate juries in civil cases, such a practice has been recognized in criminal cases. The court noted that the power to utilize separate juries in civil cases has been exercised very rarely but has not been denied, suggesting that no legal barriers exist to the proposed procedure. The court emphasized the importance of judges managing trials effectively to reduce jury confusion and support the use of inventive procedures that align with legal norms. Nonetheless, the potential for inconsistent verdicts from separate juries was acknowledged. If the ADM jury determines that ADM violated the Sherman Act by engaging in price-fixing, but the jury finds Staley did not conspire with ADM, ADM cannot be deemed guilty of conspiracy without the involvement of other firms. The verdict against ADM would imply at least one other firm conspired with it, contradicting the finding in favor of Staley. Previous defendants, like CPC International, could potentially be viewed as conspirators with ADM, regardless of Staley's involvement. However, no plausible theory supports that ADM conspired with other defendants while excluding Staley. Citing United States v. Lewis, it is noted that an inconsistency in verdicts may arise due to different evidence presented to separate juries, which would not invalidate the outcomes. The principle observed in Lewis, a criminal case, is deemed applicable to civil cases as well. The district judge was incorrect in believing he could not empanel separate juries.