People v. Roman, 46 N.Y.2d 857 (1979)
A brief and inadvertent viewing of a defendant in handcuffs by jurors is not, by itself, sufficient to warrant a mistrial and deny the defendant a fair trial.
Summary
The New York Court of Appeals affirmed the defendant’s conviction, holding that a brief and inadvertent viewing of the defendant in handcuffs by two jurors while returning from a lunch recess did not warrant a mistrial. The court reasoned that the viewing, by itself, was insufficient to deny the defendant a fair trial. Furthermore, the defense counsel declined the trial judge’s offer to deliver a curative instruction or to substitute alternate jurors, thus waiving any potential prejudice.
Facts
The defendant was on trial and during a lunch recess, two jurors inadvertently saw him in handcuffs. The defendant moved for a mistrial, arguing that the incident prejudiced the jury against him.
Procedural History
The trial court denied the defendant’s motion for a mistrial. The defendant was subsequently convicted. The defendant appealed the denial of the motion for a mistrial claiming a denial of due process. The New York Court of Appeals affirmed the trial court’s order.
Issue(s)
1. Whether the trial court erred in denying the defendant’s motion for a mistrial after two jurors inadvertently viewed him in handcuffs.
2. Whether the People proved beyond a reasonable doubt that the defendant and his accomplices caused physical injury to their victim while “effecting entry” into his dwelling, as required for a conviction of burglary in the first degree.
Holding
1. No, because the brief and inadvertent viewing of the defendant in handcuffs by the jurors was, by itself, insufficient to deny the defendant a fair trial.
2. Yes, because the People met their burden of proof on this point based on the trial record.
Court’s Reasoning
The Court of Appeals reasoned that the brief and inadvertent viewing of the defendant in handcuffs was not inherently prejudicial enough to warrant a mistrial. The court distinguished the case from situations involving more egregious or prolonged exposure. The Court emphasized that defense counsel declined the Trial Judge’s express invitation to deliver a curative instruction, and did not request the substitution of alternate jurors or an examination into the effect of the encounter. The court found this inaction to be significant. Regarding the burglary conviction, the Court of Appeals stated, “Our examination of the trial record persuades us that the People did indeed meet their burden of proof on this point,” indicating that sufficient evidence existed to support the jury’s finding that the defendant caused physical injury while effecting entry into the dwelling. The Court did not elaborate further on the evidence, but the finding suggests a fact-specific inquiry was made and resolved in favor of the prosecution.