In McDonough Power Equipment, Inc. v. Greenwood et al., the U.S. Supreme Court ruled on a case involving juror honesty during voir dire (the preliminary examination of a witness or a juror by a judge or counsel). The plaintiff, Greenwood, had sued McDonough Power Equipment after one of their lawnmowers exploded and injured him. During jury selection for this case, none of the potential jurors responded when asked if they or any close family members had ever been involved in an accident causing personal injury; however it was later discovered that one juror failed to disclose his son's accident which resulted in injuries from an exploding tire. The court held that to obtain a new trial due to dishonesty during voir dire, "a party must first demonstrate that a juror failed to answer honestly a material question...and then further show that correct response would have provided valid basis for cause challenge." In other words, not every failure of disclosure is grounds for mistrial - only those where honest answers could have shown clear bias against one party.

In the dissenting opinion for McDonough Power Equipment, Inc. v. Greenwood et al., Justice Blackmun argued that a new trial should not be granted based on juror nondisclosure during voir dire unless it is proven that the juror was biased against one of the parties involved in the case. He believed that there was no evidence to suggest any bias from Juror Tarro towards either party and therefore saw no reason to overturn the original verdict favoring Greenwood. Furthermore, he pointed out inconsistencies in how courts have handled similar situations involving potential juror bias and called for clearer guidelines on this issue moving forward.