The trial court’s denial of an in camera inspection, to ascertain a juror’s state of mind, was reversible error.

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The following is SM JUROR’s slideshare analysis of People v. Kuzdzal, 144 A.D.3d 1618, 42 N.Y.S.3d 507 (N.Y. App. Div. 2016).


In this murder trial, a spectator reported that she heard two jurors refer to the defendant as a “scumbag,” and identified the jurors to the trial court. Defense counsel asked the trial court to perform an in camera inspection of the jurors to ascertain the state of mind of each, but the court denied the request without explanation. The jury convicted the defendant, and he appealed his conviction.

View our slideshare to see how the appellate court handled the juror misconduct issue, including how to make a proper determination of a juror’s state of mind, the trial court’s obligation to hold an inquiry under such circumstances, and an examination of the trial court’s conclusory ruling.

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Don’t let juror misconduct taint your next verdict…