Written by attorneys · grounded in primary & secondary sources — see below
A jury verdict that reports only which party prevails without disclosing the jury's specific factual findings or reasoning.
Sources & Authorities
How it applies
Common Examples
6
General Verdict With Written Questions
Guillermo Guzman sued Gable Construction after a scaffold collapse. The court submitted a general verdict form together with written questions on breach and causation. The jury returned a general verdict for Guzman awarding damages and answered the questions consistently with that outcome.
Consistent Verdict And Answers
Georgia Gibbs sued Granite Holdings for breach of a supply contract. The jury returned a general verdict for Gibbs and answered written questions confirming the contract existed and was breached. The court approved judgment on the verdict and answers under the applicable rule.
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Guadalupe Gallegos sued Guardian Insurance after a denied claim. The jury returned a general verdict for Gallegos but answered written questions showing the policy excluded coverage. The court entered judgment according to the answers notwithstanding the general verdict.
Clerk Enters Judgment On Verdict
Genevieve Gardner sued Grandview Holdings for unpaid wages. The jury returned a general verdict awarding Gardner damages. The clerk promptly entered judgment on the general verdict without awaiting further court direction.
General Verdict In Conspiracy Trial
Glenn Gross was tried on multiple substantive counts arising from a conspiracy. The jury returned a general verdict of guilty on several counts. The court imposed a single sentence that remained valid because any one good count supported the judgment.
Pinkerton v. United States328 U.S. 640, 66 S.Ct. 1180, 90 L.Ed. 1489
General Verdict On Status Offense
Gretchen Graham was charged with a narcotics offense based on either use or addiction. The jury returned a general verdict finding her guilty. The court upheld the conviction because the general verdict could rest on either ground presented to the jury.
Robinson v. California370 U.S. 660, 82 S.Ct. 1417, 8 L.Ed.2d 758
Common questions
Frequently Asked
4
When may a court submit a general verdict together with written questions?+
Federal Rule of Civil Procedure 49(b)(1) authorizes the court to submit forms for a general verdict together with written questions on one or more issues of fact. The court must provide necessary instructions so the jury can render both the verdict and the answers.
What happens when a general verdict and written answers are consistent?+
Under Rule 49(b)(2) the court must approve an appropriate judgment on the verdict and answers for entry under Rule 58. The clerk may then enter the judgment promptly when the jury returns a general verdict.
How does a court handle inconsistency between a general verdict and written answers?+
Rule 49(b)(3) permits the court to enter judgment according to the answers notwithstanding the general verdict, direct the jury to deliberate further, or order a new trial when the answers are consistent with each other but inconsistent with the verdict.
Why might a general verdict create problems on appeal?+
A general verdict provides no insight into the jury's reasoning. If multiple theories were submitted and one rests on improper evidence or an erroneous instruction, an appellate court may have to reverse because it cannot determine the basis for the verdict.
376 U.S. 254 (1964)Remedies
…of the article." In answer to a special question, the jury found that the plaintiff had not proved actual malice, and a general verdict was returned for the defendant. On appeal the Supreme Court of Kansas, in an opinion by Justice Burch, reasoned as follows (78 Kan., at 724, 98 P., at 286): "It is of the utmost…