People v. Jean, 75 N.Y.2d 744 (1989)
A trial court has broad discretion to restrict the scope of voir dire by counsel, so long as the restrictions afford defense counsel a fair opportunity to question prospective jurors about relevant matters.
Summary
The New York Court of Appeals upheld a trial court’s decision to impose time limits on attorney voir dire, finding no abuse of discretion or prejudice to the defendant. The court emphasized that while restrictions on voir dire are permissible, they must allow a fair opportunity for questioning on relevant matters. The defendant failed to demonstrate that the time limits prevented him from asking necessary questions or that the jury ultimately selected was biased.
Facts
During jury selection, prospective jurors completed detailed biographical questionnaires, with clarifications provided when necessary. The trial court, over the defendant’s objection, imposed time limits on each attorney’s voir dire: 15 minutes for the first two rounds and 10 minutes for the third round. Defense counsel did not individually question every prospective juror due to these time limits but could direct questions to the panels as a group. The court offered defense counsel the opportunity to record questions he could not pose individually, but counsel did not do so.
Procedural History
The trial court convicted the defendant. The defendant appealed, arguing that the time limits on voir dire deprived him of a fair trial and an impartial jury. The Appellate Division affirmed the conviction. The case then went to the New York Court of Appeals.
Issue(s)
1. Whether the trial court abused its discretion by imposing time limits on the voir dire process.
2. Whether the time limits imposed on voir dire deprived the defendant of his constitutional right to a fair and impartial jury.
Holding
1. No, because the record does not support a conclusion that the trial court abused its discretion or that the defendant was prejudiced by the court’s exercise of its discretion.
2. No, because under the circumstances of this case, the defendant’s contention lacks merit.
Court’s Reasoning
The Court of Appeals acknowledged that trial courts have broad discretion in managing the scope of voir dire, including setting time limits, citing People v. Pepper, 59 NY2d 353, 358 and People v. Boulware, 29 NY2d 135, 140. The Court also noted the mandate in CPL 270.15 [1] [c] to preclude repetitive or irrelevant questioning. However, this discretion is not unlimited. The Court emphasized that “Any restrictions imposed on voir dire, however, must nevertheless afford defense counsel a fair opportunity to question prospective jurors about relevant matters.” The Court found no evidence that the time limits prevented defense counsel from adequately questioning prospective jurors or that the jury ultimately selected was biased against the defendant. The defendant’s failure to make a record of specific questions he was unable to ask was also considered. The Court referenced Rosales-Lopez v. United States, 451 US 182, 189-190, in rejecting the defendant’s constitutional argument.