California, United States of America
The following excerpt is from Romo v. Ford Motor Co., 122 Cal.Rptr.2d 139, 99 Cal.App.4th 1115 (Cal. App. 2002):
Defendant contends the standard of review of the order granting a new trial is abuse of discretion. Quoting Malkasian v. Irwin (1964) 61 Cal.2d 738, 748, 40 Cal. Rptr. 78, 394 P.2d 822, defendant contends, "A trial court's decision granting (as opposed to denying) a new trial on the ground of jury misconduct may be reversed `only in rare instances and on very strong grounds.'"
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