Woods v. Macrae

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Woods v. Macrae, Wythe 253 (1794),[1] was a very brief decision about whether a mistaken verdict had been proven and could cause a new trial.


There was a suit in a court of law over who had the rights to a lottery ticket. Wythe does not say who sued whom in the lower court or how the case arrived in the High Court of Chancery, but it appears that Philip Woods asked the Chancery Court to require the lower court to grant a new trial.

At the Chancery Court, several jurors from the trial in the lower court voluntarily testified that they calculated their award based on their belief that Philip Macrae had the rights to one-half of the ticket, even though ample evidence had been provided to show that Macrae was entitled to one quarter of the ticket at most.

The Court's Decision

In a single-sentence decision, Wythe ordered another trial to be held, with a reference in a footnote to Cochran v. Street.[2]


  1. George Wythe, Decisions of Cases in Virginia by the High Court of Chancery with Remarks upon Decrees by the Court of Appeals, Reversing Some of Those Decisions, 2nd ed., ed. B.B. Minor (Richmond: J.W. Randolph, 1852): 253.
  2. Wythe 133. In Cochran, the plaintiff filed a motion to stay the lower court's judgment because, among other reasons, some jurors later came forward to testify that they had made a mistake when they decided the verdict. Wythe indicated that a motion for a new trial, not a motion to stay the judgment, was the appropriate filing.