People v. Bludson, 97 N.Y.2d 644 (2001)
A prospective juror who expresses doubt about their ability to be impartial based on the law must be excused unless they unequivocally state on the record that they can be fair.
Summary
The New York Court of Appeals reversed the Appellate Division’s order and mandated a new trial. The court held that the trial court erred by denying the defendant’s challenges for cause regarding two prospective jurors who expressed doubts about their ability to render an impartial verdict. One juror indicated that they would require the defense to prove the defendant’s innocence, and another stated that the defendant’s failure to testify would negatively influence their decision. Because the trial court failed to obtain unequivocal assurances of impartiality from these jurors, the defendant was prejudiced, warranting a new trial.
Facts
During jury selection, defense counsel questioned prospective jurors about their ability to presume the defendant’s innocence, the prosecution’s burden of proof, and the defendant’s right not to testify. One prospective juror stated that they would require the defense to prove the defendant’s innocence to return a not-guilty verdict. Another prospective juror indicated that the defendant’s failure to testify would make it difficult for them to find the defendant not guilty. The trial court did not take any corrective action after these statements. The defense challenged these jurors for cause, but the challenges were denied. The defendant then used peremptory challenges to remove both jurors, exhausting all of their peremptory challenges during jury selection.
Procedural History
The defendant was tried and convicted. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the trial court erred in denying the defendant’s challenges for cause regarding two prospective jurors who expressed doubts about their ability to render an impartial verdict.
Holding
Yes, because the prospective jurors’ statements cast serious doubt on their ability to render a fair verdict under the proper legal standards, and the trial court failed to obtain unequivocal assurances from them that they could reach a verdict based entirely on the court’s instructions on the law.
Court’s Reasoning
The Court of Appeals relied on Criminal Procedure Law § 270.20 (1) (b), which allows a party to challenge a prospective juror for cause if the juror “has a state of mind that is likely to preclude him [or her] from rendering an impartial verdict based upon the evidence at the trial.” Citing People v. Arnold, 96 N.Y.2d 358, 362, the court reiterated that “a juror who has revealed doubt, because of prior knowledge or opinion, about [his or] her ability to serve impartially must be excused unless the juror states unequivocally on the record that [he or] she can be fair.” The court found that the prospective jurors’ statements indicated a predisposition that would prevent them from fairly considering the evidence and following the court’s instructions. The court emphasized that the trial court had a duty to elicit an unequivocal assurance of impartiality from the jurors, and the jury panel’s earlier collective acknowledgement was insufficient. The court stated, “We conclude that the prospective jurors’ statements cast serious doubt on their ability to render a fair verdict under the proper legal standards. The trial court therefore was required to elicit some unequivocal assurance from the two prospective jurors that they were able to reach a verdict based entirely upon the court’s instructions on the law. The jury panel’s earlier collective acknowledgment that they would follow the court’s instructions was insufficient to constitute such an unequivocal declaration”. Because the defendant was forced to use peremptory challenges to remove these biased jurors, and because he subsequently exhausted all his peremptory challenges, the error was not harmless and a new trial was required.