Is a Fast (Hasty) Jury Decision Legal ?

In Vomaska v. City of San Diego (1997), the court held a jury's decision on a verdict 10 to 15 minutes after beginning deliberations, before receiving exhibits, and without discussing the case before their vote, did not deprive a party of its constitutional right to a jury trial. (Vomaska, supra, 55 Cal. App. 4th at pp. 909-911.) In reaching this decision, we adopted the following language from an Ohio case: "While the verdict should be the result of sound judgment, dispassionate consideration, and conscientious reflection, and the jury should, if necessary, deliberate patiently and long on the issues which have been submitted to them, yet, where the law does not positively prescribe the length of time a jury shall consider their verdict, they may render a valid verdict without retiring, or on very brief deliberation after retiring, although the court may, in its discretion, cause the jury to reconsider the case if their decision is so hasty as to indicate a flippant disregard of their duties." (Id. at p. 913, quoting Val Decker Packing Co. v. Treon (1950) 88 Ohio App. 479 [97 N.E.2d 696, 701].)