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In Re High Fructose Corn Syrup Antitrust Litigation
Citations: 361 F.3d 439; 57 Fed. R. Serv. 3d 1101; 63 Fed. R. Serv. 1297; 2004 U.S. App. LEXIS 5090; 2004 WL 527033Docket: 04-8004
Court: Court of Appeals for the Seventh Circuit; March 18, 2004; Federal Appellate Court
In the antitrust class action In re High Fructose Corn Syrup Antitrust Litigation, the Seventh Circuit addressed the issue of whether to allow separate juries for defendant Archer Daniels Midland Company (ADM) and the other defendants—A.E. Staley Manufacturing Company, Cargill, Inc., and American Maize-Products Company—in light of potentially damaging evidence from criminal proceedings against ADM. The district judge expressed concern that jurors might improperly consider this evidence when assessing the liability of the other defendants. Although the judge recognized the absence of a specific rule allowing for separate juries in civil cases, he suggested the procedure to mitigate jury bias and certified the issue for immediate appeal under 28 U.S.C. § 1292(b). The appellate court clarified that while the criteria for severing claims or parties under Federal Rule of Civil Procedure 21 were not met, the general authority of judges to manage litigation permits the use of separate juries in civil cases, despite limited precedent. The court emphasized that judges are encouraged to implement creative solutions to prevent jury confusion and ensure fair trials, provided no legal norms are violated. Notably, Cargill and American Maize Products had settled with the plaintiffs, leaving Staley as the sole appellant seeking separate juries, opposed by both ADM and the plaintiffs. The district judge's proposed use of separate juries in civil cases, traditionally accepted in criminal proceedings, is deemed appropriate. Concerns arise regarding the potential for inconsistent verdicts, particularly if one jury determines that ADM violated the Sherman Act while another jury finds that Staley did not conspire with ADM. This inconsistency is problematic because ADM's liability for conspiracy hinges on collaboration with other firms. The settled defendants, including CPC International, could be implicated as conspirators with ADM, but no plausible theory supports a scenario where ADM conspired with other defendants without involving Staley. However, referencing United States v. Lewis, it is noted that such inconsistencies may not be detrimental, as different juries might hear varied evidence, leading to differing outcomes that are logically sound. The conclusion is that the district judge mistakenly believed he could not empanel separate juries.