The Tennessee Supreme Court recently clarified the standards for determining whether a jury's exposure to outside information requires a new trial. This ruling came from the case Kendal Collier ex rel. Chayce C. v. Periclis Roussis, M.D., docket number E2022-00636-SC-R11-CV, which involved a healthcare liability dispute concerning the treatment of a pregnant patient experiencing anaphylaxis.
The case has significant implications for future civil trials, particularly those involving jury misconduct. It addresses how courts should evaluate claims that a jury's verdict was influenced by information not presented during the trial.
Background
The parties involved in this case are Kendall Collier, who is representing her son Chayce, and Dr. Periclis Roussis, along with the Fort Sanders Perinatal Center and Fort Sanders Regional Medical Center. The dispute arose from an incident in June 2009, when Collier was admitted to the medical center during labor and suffered an anaphylactic reaction to medication. Afterward, her son was diagnosed with severe brain injuries, which Collier alleges were caused by the medical staff's failure to administer epinephrine during her reaction.
Collier initially filed a lawsuit against the medical personnel in 2012, claiming negligence. The jury in the first trial ruled in favor of the defendants. However, the Court of Appeals later ordered a new trial due to improper testimony being allowed. During the retrial in 2019, the jury again sided with the defendants. Following the trial, it was revealed that a juror had conducted independent research on an EpiPen and shared that information with other jurors, leading Collier to request a new trial.
The Ruling
The Tennessee Supreme Court, led by Chief Justice Jeffrey S. Bivins, ruled on July 31, 2026, stating that the trial court had not applied the correct legal standard when deciding whether to grant a new trial. The court emphasized the need for a burden-shifting framework in such cases. The court stated, "The party challenging the verdict bears the initial burden of proving error—that the jury was exposed to material extraneous information—by a preponderance of the evidence." This means that if a party can show that the jury was exposed to outside information, a presumption of prejudice arises, and the burden shifts to the defending party to prove that the exposure did not affect the jury's decision.
The court vacated the Court of Appeals' judgment and remanded the case back to the trial court for further proceedings consistent with this new framework. The ruling aims to ensure that juries remain unbiased and that verdicts are based solely on the evidence presented during the trial.
Impact
This ruling has significant implications for future civil cases in Tennessee. By establishing a burden-shifting framework, the court aims to protect the constitutional right to a fair trial by ensuring that jurors are not influenced by outside information. This decision aligns civil trial standards more closely with those used in criminal cases, where the presumption of prejudice is more commonly applied.
The ruling will affect how courts handle claims of jury misconduct in civil trials. It sets a precedent that could lead to more new trials being granted when juries are exposed to extraneous information, thereby reinforcing the integrity of the jury system.
What's Next
The case has been sent back to the trial court for further proceedings. It remains to be seen how the trial court will apply the new burden-shifting framework in this case. Additionally, there may be related cases pending that could further clarify the standards for jury misconduct in Tennessee.