In Dietz v Bouldin, 579 U. S. ____ (2016), the U.S. Supreme Court held that the federal district court has a limited inherent power to rescind a jury discharge order and recall a jury in a civil case for further deliberations after identifying an error in the jury’s verdict. The decision resolved a circuit split regarding whether and when a federal district court has the authority to recall a jury after discharging it.
