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Ravi Nathan v. Boeing Company, a Delaware Corporation

Citation: 116 F.3d 422Docket: 95-36298

Court: Court of Appeals for the Ninth Circuit; August 27, 1997; Federal Appellate Court

Narrative Opinion Summary

In this case, an appellant contested a verdict favoring the opposing corporate party, challenging the district court's decision not to exclude two jurors employed by the corporation. The appellant argued that Washington law required their removal due to their employment status. However, the court examined whether federal or state law governed jury selection challenges, ultimately applying federal law under 28 U.S.C. § 1870, which grants the district court discretion in such matters. The appellate court reviewed the district court's decisions de novo, applying the abuse of discretion standard, and upheld the lower court's rulings. The appellant's claims of bias due to employment relationships were deemed insufficient to presume bias without a direct threat of violence or similar risk. Additionally, the court dismissed the argument that judicial notice was improperly taken concerning jurors' potential stock ownership. The court's analysis supported the flexible application of federal procedural rules over rigid state laws, affirming that no abuse of discretion occurred and upholding the original verdict in favor of the corporate party.

Legal Issues Addressed

Abuse of Discretion Standard in Jury Selection

Application: The appellate court reviewed the district court's refusal to remove jurors for potential bias under the abuse of discretion standard, concluding no abuse occurred.

Reasoning: The district court's refusal to remove two Boeing employees from the jury panel is reviewed for abuse of discretion.

Federal Law Supremacy in Jury Selection

Application: The court determined that federal law under 28 U.S.C. § 1870 governs challenges for cause in jury selection, superseding state law prohibitions against employees serving on juries involving their employers.

Reasoning: 28 U.S.C. § 1870 mandates that all challenges for cause regarding jurors be determined by the court, granting the district court discretion in assessing such challenges.

Judicial Notice and Juror Bias

Application: The court rejected the appellant's contention that the district court's comment on potential stock ownership of jurors amounted to judicial notice, as no formal notice was taken.

Reasoning: Nathan's argument that the district court's comment on the jurors' potential stock ownership constituted judicial notice was rejected.

Presumption of Juror Bias

Application: The court found no presumption of bias for jurors employed by a party when no direct threat of violence or comparable risk existed, as argued by the appellant.

Reasoning: Nathan's assertion that the jurors feared retaliation from Boeing was insufficient to establish a comparable risk.