People v. Rentz, 67 N.Y.2d 829 (1986)

A juror with a prior relationship with a witness may be disqualified, particularly if the witness’s testimony pertains to a central issue in the case, and the parties should be informed of any communication from a juror regarding potential bias before the court makes a ruling.

Summary

Defendant Rentz’s murder conviction was challenged based on the trial court’s failure to disqualify a juror who had a prior relationship with two prosecution witnesses. The New York Court of Appeals reversed the Appellate Division’s order affirming the denial of Rentz’s motion to vacate the judgment, ordering a new trial. The court held that the juror’s relationship with the witnesses, who testified on the critical issue of Rentz’s sanity, created implied bias, requiring disqualification. The court also emphasized the importance of informing the parties of any communication from a juror regarding potential bias before the court makes a ruling.

Facts

Rentz was convicted of murder in 1976, and the conviction was affirmed. In 1982, Rentz moved to vacate the conviction, arguing that the trial court erred by not disqualifying a juror who had a prior relationship with two prosecution witnesses. The juror was acquainted with two prosecution witnesses; the relationship was described as professional, but with one witness, it was also “somewhat intimate.” The two witnesses testified to refute Rentz’s claim of insanity, the primary issue at trial.

Procedural History

The trial court denied Rentz’s motion to vacate the conviction. The Appellate Division affirmed the trial court’s decision. Rentz appealed to the New York Court of Appeals.

Issue(s)

1. Whether the trial court erred in failing to disqualify a juror who had a prior relationship with two prosecution witnesses.
2. Whether the court should inform the parties of the communication from the juror before the court rules on its effect.

Holding

1. Yes, because the juror’s prior relationship with the prosecution witnesses, who testified on the critical issue of Rentz’s sanity, created implied bias, which should have resulted in disqualification (CPL 270.35).
2. Yes, because parties should be given an opportunity to be heard before the court rules on a matter relating to the case.

Court’s Reasoning

The Court of Appeals reasoned that while a prior relationship with a witness does not automatically disqualify a juror, it may require excusal in certain cases. In this instance, the juror’s relationships with two prosecution witnesses, particularly given their testimony on the crucial issue of Rentz’s sanity, created implied bias. The court noted that the juror’s statement that the relationship would not affect impartiality is ineffective when implied bias is shown, citing People v. Branch, 46 N.Y.2d 645. The court emphasized that, considering all circumstances, the trial court should have found the juror unqualified. Regarding communication with the parties, the court stated: “Finally we emphasize that the court should have informed the parties of the communication from the juror before the court ruled on its effect…the parties should, in most, if not all cases, be given an opportunity to be heard before the court rules on such a matter relating to the case.” The court also noted a potential claim of ineffective assistance of counsel but did not address it due to the decision on juror disqualification.