William O. Compton, Petitioners v. Louis C. Henrie, Respondent

Summary

The Texas Supreme Court held that juror Fugate was not disqualified for bias and that his statements during deliberations did not constitute jury misconduct, so the trial court's judgment was affirmed and the Court of Civil Appeals reversed. The Court clarified that bias against the type of suit can be disqualifying, but found no such bias here, and that a juror's misinterpretation of the charge is not misconduct under Rule 327. The Court also reiterated that when a juror is disqualified, probable injury need not be shown before granting a new trial. Justice Griffin dissented, arguing that the Court of Civil Appeals was correct.