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.