People v. Branch, 97 N.Y.2d 623 (2001)

When a juror makes statements during deliberations indicating a lack of understanding of the proceedings, lawyers, or judge, the trial court has a duty to conduct a probing inquiry to determine whether the juror is grossly unqualified, without intruding into the jury’s deliberative process.

Summary

During jury deliberations in a criminal trial, a juror informed a court officer that she did not understand the proceedings, lawyers, or judge. The court, alerted to this issue, took the verdict without adequately addressing the juror’s concerns. The New York Court of Appeals reversed the Appellate Division order and ordered a new trial, holding that the trial court’s inquiry into the juror’s qualifications was insufficient. The Court emphasized that a “probing and tactful inquiry” is required when a juror’s competence is questioned, focusing on understanding and not delving into the deliberative process itself.

Facts

During jury deliberations, a juror told a court officer that she