People v. Pizarro, 7 N.Y.3d 830 (2006)
A trial court’s credibility findings regarding juror impartiality, made after a hearing and based on observations of the jurors, are entitled to great deference on appeal, provided they are supported by the record.
Summary
Defendant Pizarro appealed his conviction, arguing that the trial judge should have declared a mistrial because a juror allegedly concealed knowledge about the case during jury selection, attempted to share outside information during deliberations, and lied to the court about it. The trial court conducted a hearing, interviewing the juror and other jurors. The court concluded that the juror did not possess outside knowledge and had not tried to convey such information. The Appellate Division affirmed, deferring to the trial court’s credibility findings. The New York Court of Appeals affirmed, holding that the trial court’s findings were supported by the record and deserved deference.
Facts
Pizarro was convicted on four counts of second-degree murder. During jury deliberations, the jury foreperson reported that another juror had attempted to share information about the case that was not part of the evidence presented at trial. Pizarro argued this warranted a mistrial.
Procedural History
Following the jury foreperson’s report, the trial court held a hearing. The trial judge interviewed the allegedly errant juror three times and also questioned the other jurors. The trial court found that the juror did not possess outside knowledge and did not attempt to share any such knowledge with the other jurors. The Appellate Division affirmed the conviction, deferring to the trial court’s findings. The New York Court of Appeals then affirmed the Appellate Division’s order.
Issue(s)
Whether the trial court erred in not declaring a mistrial based on the allegation that a juror concealed personal knowledge about the case, attempted to share outside-the-record information with other jurors, and then lied to the trial court about these actions.
Holding
No, because the trial court’s credibility findings, made after hearing and viewing the jurors, are entitled to great deference, and the record supported the court’s determination that there was no juror misconduct warranting a mistrial.
Court’s Reasoning
The Court of Appeals emphasized the deference owed to the trial court’s credibility determinations, stating that such findings are “entitled to great deference.” The Court found that the juror repeatedly denied having extrinsic knowledge, and the trial judge credited these denials. The Court noted that the Appellate Division had also deferred to the trial court’s findings, observing that there was merely a “misunderstanding” between the juror and some of the other jurors. The Court of Appeals further explained that it must accept the affirmed factual determinations of the lower courts if they are supported by the record, which they were in this case. The court found no basis to overturn the trial court’s assessment of the juror’s credibility, particularly since the juror’s denials were not, as a matter of law, contradicted by the other jurors’ accounts. The court implied that absent clear and convincing evidence of juror misconduct or bias, deference should be given to the trial court’s first-hand observations and findings.