People v. Rukaj, 51 N.Y.2d 529 (1980)

When a juror expresses having reached a verdict under duress during polling, the trial court must conduct a specific inquiry to determine the nature and source of the duress without violating the secrecy of jury deliberations, and then determine appropriate remedial action.

Summary

During the polling of the jury, one juror stated that her verdict was given “under duress.” Defense counsel requested a hearing to determine the nature of the duress, but the trial court denied the request. The New York Court of Appeals held that the trial court erred in failing to conduct an inquiry into the juror’s claim of duress. The Court outlined a specific procedure for the judge to follow, balancing the need to investigate potential coercion with the importance of maintaining the secrecy of jury deliberations. The Court stated the trial court should have questioned the juror to ascertain whether the duress arose from extraneous matters and then taken remedial action as needed.

Facts

After the jury announced its verdict, the defense requested that the jury be polled. When asked whether the verdicts were hers, one juror responded, “Yes, under duress, I’m saying yes”. Defense counsel then requested the court to hold a hearing to determine the nature of the stated duress. The trial court denied this request and accepted the verdict.

Procedural History

The defense appealed the trial court’s decision. The Appellate Division reversed the trial court’s judgment, finding that the trial court should have inquired into the juror’s claim of duress. The prosecution appealed to the New York Court of Appeals, which affirmed the Appellate Division’s order.

Issue(s)

Whether a trial court errs when it fails to inquire into a juror’s statement during polling that their verdict was given under duress.

Holding

Yes, because the trial court had a duty to investigate the juror’s claim to determine if the duress arose from improper influences without compromising the secrecy of jury deliberations and to take appropriate remedial action if necessary.

Court’s Reasoning

The Court of Appeals determined that the trial court erred by not inquiring into the juror’s claim of duress. The Court established a specific procedure for handling such situations. The trial judge should question the juror privately, instructing them not to disclose the content of jury deliberations. The judge should then inquire whether the juror can describe the circumstances of the duress without violating the secrecy of deliberations. If the juror can do so, the judge should listen, being careful to prevent disclosure of the deliberative process. If the duress arises from matters extraneous to the jury’s deliberations, the judge must determine what remedial action is suitable, which could range from directing the jury to continue deliberating to declaring a mistrial. The Court emphasized the importance of maintaining jury secrecy while also ensuring that verdicts are not the product of coercion: “communications among the jurors that were a part of their deliberative process in attempting to reach a verdict on the issues they were charged to decide (including their efforts by permissible arguments on the merits to persuade each other) were secret and not to be disclosed to him.” The Court criticized the trial court’s limited inquiry, which gave the juror “only the categorical alternative of ‘yes or no’, with no opportunity even to volunteer any comment or exposition of the predicament in which she found herself.” The appropriate action depends on the specific facts and the effectiveness of any procedure to eradicate the effect of the duress.