Jury Bias And Misconduct
Jury Bias and Misconduct
Jury bias refers to situations where a juror holds preconceived opinions, prejudices, or is influenced by external factors that prevent them from being impartial. Jury misconduct refers to inappropriate behavior by jurors during the trial or deliberations, such as discussing the case outside the courtroom, reading media reports, conducting independent investigations, or being influenced by personal relationships. Both can undermine the fairness of a trial and are grounds for appeals or mistrials.
1. Sources of Jury Bias and Misconduct
Pretrial publicity – Jurors may have read or heard news reports creating preconceived notions.
Personal relationships – Knowing parties, witnesses, or attorneys.
External communications – Discussing the case with outsiders.
Independent investigation – Researching the facts outside of court.
Improper behavior – Intoxication, coercion among jurors, or viewing evidence not presented in court.
Case Laws Illustrating Jury Bias and Misconduct
1. Irvin v. Dowd (1961) – U.S. Supreme Court
Facts: Leslie Irvin was convicted of murder. There had been extensive newspaper coverage portraying him as guilty. When jury selection occurred, several jurors admitted they had formed opinions based on media reports.
Issue: Can a defendant receive a fair trial when jurors are exposed to prejudicial pretrial publicity?
Holding: The Supreme Court held that Irvin’s right to an impartial jury under the Sixth Amendment was violated due to juror bias. The conviction was overturned.
Significance: This case establishes that extensive pretrial publicity can create presumptive bias and violate the defendant’s rights.
2. Remmer v. United States (1954) – U.S. Supreme Court
Facts: After a conviction, it was discovered that a juror had been approached by a person offering a bribe to influence the verdict.
Issue: How should courts handle post-trial evidence of jury bribery?
Holding: The Court held that any private communication with a juror about the case, especially bribery, is presumed prejudicial. Courts must investigate to ensure no improper influence occurred.
Significance: Establishes the principle that jury tampering or bribery is automatically considered prejudicial, and courts must act to protect trial integrity.
3. Tanner v. United States (1987) – U.S. Supreme Court
Facts: After a drug conspiracy trial, it was alleged that jurors had been consuming alcohol and drugs during deliberations.
Issue: Could this misconduct justify a new trial?
Holding: The Court ruled that the juror’s internal deliberations and behavior (like intoxication) are generally not admissible for a new trial. Instead, the proper remedy is through voir dire and other safeguards.
Significance: Shows limits on challenging verdicts based on internal juror misconduct versus external influences.
4. R. v. Abdroikoff (Canada, 1985)
Facts: In this criminal trial, a juror was discovered to have done independent research about the defendant online and shared it with other jurors.
Issue: Does independent investigation by a juror constitute juror misconduct?
Holding: The court held that jurors cannot bring outside information to deliberations. This behavior undermines the fairness of the trial, and a new trial may be required if the misconduct could influence the verdict.
Significance: Reinforces that jurors must rely solely on evidence presented in court.
5. R. v. Twomey (UK, 2009)
Facts: Some jurors were found to have communicated with outsiders about the case and accessed news reports about ongoing proceedings.
Issue: Can external communications during trial be grounds for setting aside a verdict?
Holding: The Court of Appeal quashed the conviction, noting that jurors must be free from external influence, and any breach can constitute misconduct sufficient to void a trial.
Significance: Highlights that any form of extraneous communication by jurors threatens the integrity of the jury system.
6. McDonough Power Equipment, Inc. v. Greenwood (1984) – U.S. Supreme Court
Facts: A juror in a civil case failed to disclose prior negative experiences with a product similar to the one in the lawsuit.
Issue: Can a verdict be challenged if a juror conceals relevant information during voir dire?
Holding: The Court allowed a new trial, emphasizing that failure to disclose potential bias during jury selection can undermine impartiality.
Significance: Juror honesty during voir dire is crucial for fair trials.
Summary of Key Principles
Impartiality is fundamental: Any bias, actual or perceived, can result in overturning convictions.
External influence vs internal deliberation: Courts treat outside interference (media, bribery, communication) more seriously than internal juror thought processes.
Voir dire is critical: Screening jurors for potential bias protects trial integrity.
Misconduct remedies: Include new trials, jury removal, or in extreme cases, conviction reversal.
RELATED Blog
comments