How have courts reviewed the findings of a jury in a civil case?

The trial court found no jury misconduct. Appellant never argues this finding was unsupported by substantial evidence. (People v. Camino (2010) 188 Cal.App.4th 1359, 1364, 1370 [a trial court's factual findings are reviewed under the substantial evidence test].) As a result, appellant fails to meet his appellate burden of establishing trial court error. (People v. Foss (2007) 155 Cal.App.4th 113, 126 ["When an appellant fails to apply the appropriate standard of review, the argument lacks legal force"].) As to the merits, we perceive no defect in the finding. The foreperson indicated that the jury was in a rush to sign the verdict forms, and that its rush resulted in an error. On its face, this did not equate to the jury being in a rush to reach the verdicts themselves. The suggestion by appellant that the jury sped up its deliberations to accommodate the religious obligations of one juror and therefore failed to fully deliberate is based solely on the speculation of appellant's counsel. Consequently, there is no basis to conclude the trial court was required to find that the jury had lost its impartiality.

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