(CN) - A trial court violated a woman's Sixth Amendment rights in dismissing the lone juror who seemed inclined to acquit on murder charges, against objections from other jurors, the 9th Circuit ruled Monday.
Tara Sheneva Williams had been the driver for two friends planning a robbery. While casing out stores one afternoon in October 1993, one member of the trio went into a liquor store alone, emptied the cash register and shot and killed the store's owner.
Williams was convicted of special circumstances murder and a firearm enhancement only after the trial court dismissed a holdout juror and replaced him with an alternate.
On appeal in Pasadena, Calif., a three-judge panel said that the action taken against that holdout juror violated Williams' rights.
The 44-page decision opens by juxtaposing interviews with the jury in Williams' case against the fictional jury-room debate in "Twelve Angry Men," the 1957 Academy Award-winning film.
When the jury foreman in Williams' trial reported the holdout, the court questioned each juror at length and dismissed Juror No. 6 because it found that he was biased against the prosecution and had lied in court.
Writing for the three-judge panel, Judge Stephen Reinhardt said the decision to remove may have impermissably stemmed from Juror No. 6's views of the merits of the case. It seems likely that the trial court did not rely on good cause to remove the juror, in violation of Williams' Sixth Amendment rights, the appellate judges added.
"The only good cause relied upon for dismissal of Juror No. 6 was 'actual bias,'" Reinhardt wrote. "The court did not find, however, that Juror No. 6 was 'biased' in any traditional sense of the term, as would have been the case if, for example, he had stated that he could not be impartial or had accepted a bribe related to the case. Nor did it find that he had 'implied bias,' such as might have resulted from Juror No. 6 having a connection to one of the parties, or being related to someone who had either committed or been a victim of some similar crime."
Furthermore the record directly contradicts the court's holding that Juror No. 6 had lied in court, according to the 44-page ruling.
"A hung jury is never a desirable outcome in a criminal trial," Reinhardt concluded. "When a mistrial results, the interest shared by the State, the defendant, the court, and the public in the efficient administration of justice is diminished. The sacrifice of efficiency for the preservation of liberty is central, however, to the safeguards the Constitution affords criminal defendants. ... Unfortunately, the trial court cut some corners here. In view of the reasonable possibility that Juror No. 6's discharge was directly or indirectly the result of his position on the merits of the case, and in view of the lack of good cause to justify his dismissal, we hold that the removal of Juror No. 6 deprived Williams of her right to a fair trial by jury."
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