People v. Maragh, 94 N.Y.2d 569 (2000)
A jury verdict can be overturned when jurors use their professional expertise to evaluate evidence, reach conclusions outside of the presented evidence, and share those conclusions with other jurors, thereby becoming unsworn witnesses.
Summary
Defendant was convicted of criminally negligent homicide. During deliberations, two nurse-jurors shared their professional opinions about the volume of blood loss necessary to cause ventricular fibrillation, contradicting expert testimony presented at trial. The trial court set aside the verdict, finding juror misconduct. The Appellate Division reversed, but the Court of Appeals reversed the Appellate Division, holding that the nurse-jurors’ actions constituted improper influence because they injected non-record evidence into deliberations, undermining the defendant’s right to a fair trial. The court emphasized that jurors can use everyday experiences but not specialized knowledge to contradict trial evidence.
Facts
The defendant was charged with manslaughter after his girlfriend died. The prosecution argued the cause of death was blunt force trauma, while the defense contended it was a venous air embolism or a cardiac event possibly related to improperly administered CPR. Expert witnesses for both sides presented conflicting medical evidence, particularly regarding the amount of blood loss and its potential effects. After the jury convicted the defendant of criminally negligent homicide, it was revealed that two jurors, both nurses, used their professional knowledge to assess the victim’s blood loss, sharing their opinions on whether it could have caused ventricular fibrillation.
Procedural History
The jury found the defendant guilty of criminally negligent homicide. The defendant moved to set aside the verdict under CPL 330.30, alleging juror misconduct. The trial court granted the motion, but the Appellate Division reversed and reinstated the guilty verdict. The New York Court of Appeals granted leave to appeal.
Issue(s)
- Whether the use of personal professional expertise by jurors, communicated to the entire jury during deliberations, constitutes juror misconduct that warrants a new trial?
Holding
- Yes, because the jurors became unsworn witnesses, injecting non-record evidence into the jury’s deliberative process, thereby prejudicing the defendant’s right to confront and cross-examine witnesses.
Court’s Reasoning
The Court of Appeals reasoned that while jurors are expected to use their everyday experiences, they cannot inject professional expertise to contradict trial evidence. The Court emphasized the potential prejudice when jurors with specialized knowledge share their opinions, as other jurors are likely to defer to this expertise. The Court distinguished between permissible application of everyday experience and impermissible injection of professional expertise which serves as non-record evidence that the defendant cannot test or refute. Quoting People v. Stanley, 87 N.Y.2d 1000, 1001, the court stated jurors cannot become “unsworn witnesses, incapable of being confronted by defendant,” by injecting expertise and nonrecord evidence into deliberations. The court also noted the importance of a jury representing a fair cross-section of the community, but stressed that even professional jurors must decide cases based only on presented evidence. The Court suggested trial courts modify standard jury instructions to differentiate between ordinary and professional opinions, explicitly directing jurors not to introduce facts and evidence from outside the record based on their professional expertise.