Diego Rodriguez v. St. Luke's Health System, Ltd., et al.

This case arises from a state-court civil judgment in which liability was not adjudicated. The trial court entered a default against petitioner as a discovery sanction, deeming the allegations of the complaint admitted. A jury proceeding limited to damages followed, and a judgment of approximately $51,875 million—of which approximately $25,375 million was punitive—was entered against petitioner jointly and severally with other defendants. A jury’s impartiality is not a courtesy extended to the parties. It is the condition on which the jury’s power to decide rests at all. This case asks what remains of that principle when a juror’s bias is admitted, on the record, and the juror is seated anyway. The questions presented are:

1. Whether the Fourteenth Amendment permits a civil judgment to stand where jurors who acknowledged bias were seated, when the structural guarantee of an impartial tribunal—as distinct from a party’s personal challenge rights—does not depend for its existence on any litigant’s timely objection.

2. Whether the Due Process Clause permits a substantial punitive damages award where the liability predicate for that award was established by discovery-sanction default rather than by adjudication, such that the reprehensibility determination central to BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996), and State Farm Mutual Automobile Insurance Co. y. Campbell, 538 U.S. 408 (2003), rests on a presumption rather than on proof tested by an adversary.