New York Law Review

Tag: impeachment of verdict

  • People v. De Lucia, 20 N.Y.2d 275 (1967): Admissibility of Juror Statements Regarding Unauthorized Site Visits

    People v. De Lucia, 20 N.Y.2d 275 (1967)

    Juror statements regarding unauthorized visits to the crime scene are admissible to demonstrate prejudice to the defendant, as such outside influences violate the defendant’s Sixth Amendment right to confront witnesses.

    Summary

    Defendants De Lucia and Montella were convicted of attempted burglary and possession of burglar’s instruments. After the initial conviction was upheld, the U.S. Supreme Court decided Parker v. Gladden, prompting reconsideration. The key issue was whether juror statements about an unauthorized visit to the crime scene were admissible to challenge the verdict. The New York Court of Appeals held that such statements were admissible, as unauthorized visits constitute inherently prejudicial “outside influences” violating the defendant’s Sixth Amendment rights. The court balanced the policy against juror harassment with the defendant’s right to a fair trial. The case was remitted for a hearing to substantiate the allegations.

    Facts

    De Lucia and Montella were convicted of attempted burglary and possession of burglar’s instruments. After the verdict, information surfaced suggesting that several jurors had visited the scene of the alleged crime without authorization and even re-enacted the crime.

    Procedural History

    The Appellate Division affirmed the initial conviction. The New York Court of Appeals initially upheld the conviction. The U.S. Supreme Court denied certiorari. Subsequently, after the Parker v. Gladden decision, the Second Circuit vacated the District Court’s dismissal of a habeas corpus petition and remanded the case to the New York courts for reconsideration in light of Parker v. Gladden.

    Issue(s)

    Whether juror statements concerning an unauthorized visit to the scene of the crime are admissible to impeach their verdict and demonstrate prejudice to the defendant.

    Holding

    Yes, because in cases involving inherently prejudicial “outside influences” on a jury, such as an unauthorized visit to the crime scene, the violation of the defendant’s Sixth Amendment rights outweighs the policy reasons for the rule against jurors impeaching their own verdicts.

    Court’s Reasoning

    The Court of Appeals acknowledged the traditional rule against jurors impeaching their own verdicts, which aims to prevent post-trial harassment of jurors and maintain the integrity of jury deliberations. However, the court also recognized the defendant’s fundamental right to a fair trial by an impartial jury. Citing Parker v. Gladden, the court emphasized that a defendant has the right to confront witnesses against them. The court distinguished between statements regarding juryroom deliberations, which are generally inadmissible, and statements concerning “outside influences,” which are more susceptible to proof and less likely to undermine the jury system. The court reasoned that the unauthorized visit transformed the jurors into unsworn witnesses against the defendants, violating their Sixth Amendment rights. As the court stated, “in the case of such inherently prejudicial ‘outside influences’ on a jury as were here present, the violation of the defendants’ Sixth Amendment rights outweighs the policy reasons for the rule.” The court held that proof of the unauthorized visit is sufficient to warrant a new trial without demonstrating how the visit influenced individual jurors. The court remitted the case for a hearing to determine if the allegations were substantiated, and if so, to vacate the convictions and order a new trial.

  • People v. De Lucia, 20 N.Y.2d 275 (1967): Juror Misconduct and Impeachment of Verdicts

    People v. De Lucia, 20 N.Y.2d 275 (1967)

    Jurors cannot impeach their own duly rendered verdict by statements or testimony averring their own misconduct, whether inside or outside the jury room, especially through hearsay affidavits.

    Summary

    Defendants appealed their conviction, arguing the trial court erred in denying their motion for a new trial based on juror misconduct. Their counsel’s affidavit alleged that jurors visited the crime scene to better understand the evidence. The New York Court of Appeals affirmed the conviction, holding that jurors cannot impeach their own verdict with statements about their misconduct, particularly through hearsay. The court emphasized that public policy prohibits such impeachment, and absent proof of substantial prejudice to the defendants, an unauthorized view of the premises does not automatically warrant a new trial. The court also found sufficient evidence to support the conviction and no prejudicial error in the arresting officer’s testimony.

    Facts

    The defendants were convicted after a trial. Following the verdict, the defendants’ trial counsel submitted an affidavit alleging that certain jurors had visited the crime scene, located across the street and about a block from the courthouse, to better understand the evidence presented at trial. The affidavit was based on statements allegedly made by the jurors to the defense counsel after the trial.

    Procedural History

    The trial court denied the defendants’ motion to set aside the verdict and for a new trial based on the juror misconduct allegations. The appellate division affirmed this decision. The New York Court of Appeals granted permission for a joint appeal to review the lower court’s affirmance.

    Issue(s)

    1. Whether jurors can impeach their own verdict through statements or testimony regarding their misconduct outside the jury room, particularly when presented as hearsay affidavits.
    2. Whether an unauthorized viewing of the crime scene by jurors, without proof of prejudice to the defendants, warrants a new trial.

    Holding

    1. No, because public policy prohibits jurors from impeaching their own verdicts based on allegations of misconduct, especially when those allegations are presented in hearsay form.
    2. No, because absent competent proof of substantial prejudice affecting the verdict, an unauthorized viewing of the premises is not, by itself, grounds for a new trial.

    Court’s Reasoning

    The court reasoned that it has long been established law that jurors cannot impeach their own verdicts through statements about their misconduct, whether inside or outside the jury room. This rule is grounded in sound public policy, aiming to preserve the finality and integrity of jury verdicts. The court cited precedents such as People v. Sprague and Dalrymple v. Williams to support this principle. The court noted that even the federal courts adhere to this policy, precluding jurors from testifying about their misconduct, citing McDonald v. Pless.

    Regarding the unauthorized view of the premises, the court acknowledged it as improper, but not automatically grounds for a new trial. The court emphasized that the defendants must demonstrate substantial prejudice resulting from the juror’s actions. Citing People v. Johnson, the court reiterated that absent competent proof of prejudice to the defendants’ substantial rights, the motion for a new trial was properly denied. The court found no evidence of such prejudice in this case.

    The court further stated, “Even though an unauthorized view of such premises is improper it is not, without more, such an impropriety as to require the granting of a new trial”.

    The court also dismissed other assigned errors, finding sufficient proof to support the conviction and no prejudicial error in the arresting officer’s testimony regarding identification.