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defendantappealhearingtrialverdictmotionwillvoir diregrand jurydeliberation

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Nash v. State, 439 Md. 53, 94 A.3d 23

Facts

Troy Sherman Nash was indicted for first-degree murder following the death of Vanessa Riddick. The trial began on August 30, 2011, and after several days of testimony, the jury began deliberations on September 2, 2011. During deliberations, the jury foreperson sent a note to the court expressing concern that a juror was willing to change her vote to guilty simply to go home. The trial judge decided to excuse the jury for the day and instructed them to return after the holiday weekend to continue deliberations. Nash's defense counsel moved for a mistrial based on the note, but the trial judge denied the motion, leading to Nash's conviction and subsequent appeal.

On 17 December 2009, a grand jury, sitting in Prince George's County, returned an indictment charging Troy Sherman Nash with one count of murder in the first degree, based on an investigation into the death of Vanessa Riddick. The case proceeded to trial in the Circuit Court for Prince George's County, beginning with jury selection on Tuesday, 30 August 2011. On Friday, 2 September 2011, the jury began hearing evidence at 10:14 AM. At 5:02 PM, the court received a note from the jury (the 'Note'), which read literally: 'I dont believe the defendant is being give a fair verdict based on one of the juror stating out loud that she will vote guilty because she want to go home and not return! When she previously said no guilty.' The Note was signed by the foreperson and dated '9/2/11.'

Issue

Did the trial court commit reversible error when, after receiving a jury note stating that one juror indicated a willingness to change her vote from not guilty to guilty 'because she want[ed] to go home and not return,' it (1) denied the defendant's mistrial motion without first conducting voir dire of the jury, (2) refused defense counsel's request to give a modified Allen instruction, and (3) chose to recess over a three-day weekend and have the jurors return to continue deliberations?

Did the trial court commit reversible error when, after receiving a jury note stating that one juror indicated a willingness to change her vote from not guilty to guilty 'because she want[ed] to go home and not return,' it (1) denied the defendant's mistrial motion without first conducting voir dire of the jury, (2) refused defense counsel's request to give a modified Allen instruction, and (3) chose to recess over a three-day weekend and have the jurors return to continue deliberations?

Rule

The court held that a trial judge has discretion in managing jury deliberations and that a juror's remark does not automatically create a presumption of prejudice requiring further inquiry unless it constitutes misconduct that compromises the jury's ability to render a fair verdict. The court also noted that a mistrial is an extreme remedy that should not be ordered lightly.

The court held that a trial judge has discretion in managing jury deliberations and that a juror's remark does not automatically create a presumption of prejudice requiring further inquiry unless it constitutes misconduct that compromises the jury's ability to render a fair verdict. The court also noted that a mistrial is an extreme remedy that should not be ordered lightly.

Analysis

The court found that the trial judge did not abuse her discretion in denying the mistrial motion. The alleged juror misconduct did not rise to a level that would compromise the jury's impartiality, and the trial judge's decision to recess for the weekend was deemed a reasonable response to the jury's note. The court emphasized that the trial judge's actions were appropriate given the circumstances and that the defense did not demonstrate that the juror's statement had a prejudicial effect on the verdict.

The court found that the trial judge did not abuse her discretion in denying the mistrial motion. The alleged juror misconduct did not rise to a level that would compromise the jury's impartiality, and the trial judge's decision to recess for the weekend was deemed a reasonable response to the jury's note. The court emphasized that the trial judge's actions were appropriate given the circumstances and that the defense did not demonstrate that the juror's statement had a prejudicial effect on the verdict.

Conclusion

The Court of Appeals affirmed the judgment of the Court of Special Appeals, concluding that the trial court did not err in its handling of the jury note or in denying the mistrial motion. Nash's conviction for first-degree murder was upheld.

The Court of Appeals affirmed the judgment of the Court of Special Appeals, concluding that the trial court did not err in its handling of the jury note or in denying the mistrial motion. Nash's conviction for first-degree murder was upheld.

Who won?

The State prevailed in the case because the court found that the trial judge acted within her discretion and that the juror's remark did not constitute misconduct that would compromise the jury's ability to render a fair verdict.

The State prevailed in the case because the court found that the trial judge acted within her discretion and that the juror's remark did not constitute misconduct that would compromise the jury's ability to render a fair verdict.

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