Oakland Raiders v. National Football League

Code of Civil Procedure section 657 (hereafter section 657) requires that an order granting a new trial specify not only the ground for the order but also “the court’s reason or reasons for granting the new trial upon each ground stated.” Here, the trial court granted plaintiff The Oakland Raiders’ motion for a new trial on the ground of jury misconduct, but the court failed to set out the required specification of reasons for granting a new trial based on jury misconduct.

Although ordinarily an order granting a new trial is reviewed only for abuse of discretion, the Court of Appeal held that an order lacking an adequate specification of reasons is subject to independent review. Under that standard of review—one that gives no deference to the trial court’s ruling— the Court of Appeal overturned the order granting a new trial and consequently affirmed the verdict and judgment against the Raiders. We agree with the analysis and conclusion of the Court of Appeal, and therefore we affirm the judgment of that court.

*629 I. Factual and Procedural Background

A. Facts Leading to the Raiders’ Move from Los Angeles

The Oakland Raiders is a professional football team owned by…

I join in the judgment affirming the Court of Appeal and concur generally in the majority’s analysis under the particular circumstances of this case. Had the trial court supported its order granting a new trial with an adequate statement of reasons, we would have been bound to defer to the trial court’s resolution of the factual conflicts in the affidavits concerning the existence of juror misconduct. (Weathers v. Kaiser Foundation Hospitals (1971) 5 Cal.3d 98, 108-109 [ 95 Cal.Rptr. 516 , 485 P.2d 1132 ].) In that event, it appears that the Oakland Raiders would have been entitled to the benefit of the new trial order, inasmuch as the National Football League has not contended here that the new trial order was invalid under an abuse-of-discretion standard. The Raiders snatch defeat from the jaws of victory in this proceeding only because the trial court failed to comply with its “mandatory” duty to specify the reasons for its order granting a new trial (Sanchez-Corea v. Bank of America (1985) 38 Cal.3d 892, 896 [ 215 Cal.Rptr. 679 , 701 P.2d 826 ]) and because the Raiders, on this record, failed to discharge their burden of persuading the reviewing court that a new trial should…

Code of Civil Procedure section 657 (hereafter section 657) requires that an order granting a new trial specify not only the ground for the order but also "the court's reason or reasons for granting the new trial upon each ground stated." Here, the trial court granted plaintiff Oakland Raiders' motion for a new trial on the ground of jury misconduct, but the court failed to set out the required specification of reasons for granting a new trial based on jury misconduct.

Although ordinarily an order granting a new trial is reviewed only for abuse of discretion, the Court of Appeal held that an order lacking an adequate specification of reasons is subject to independent review. Under that standard of review — one that gives no deference to the trial court's ruling — the Court of Appeal overturned the order granting a new trial and consequently affirmed the verdict and judgment against the Raiders. We agree with the analysis and conclusion of the Court of Appeal, and therefore we affirm the judgment of that court.

The Oakland Raiders is a professional football team owned by Al Davis, with a membership in the National Football League (NFL), which is an unincorporated…