People v. Arnold
729 N.Y.S.2d 51, 96 N.Y.2d 358, 753 N.E.2d 846 (2001)
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Rule of Law:
When a prospective juror expresses serious doubt about their ability to be impartial, the trial court must dismiss that juror for cause unless the juror provides an unequivocal, personal assurance on the record that they can be fair. A general acknowledgment by the entire panel is insufficient to cure the potential bias of an individual juror.
Facts:
- The defendant was on trial for assaulting his former girlfriend by stabbing her.
- The defendant claimed he acted in self-defense after she attacked him with a razor blade.
- During jury selection, Prospective Juror Number 4 stated she had a bachelor's degree in sociology with a minor in women's studies and had done extensive research on domestic violence and battered women's syndrome.
- The prospective juror stated, 'I have a problem with that,' when asked if her background would affect her ability to sit on the case.
- When asked if she might become an 'expert' witness in the jury room because of her studies, she responded, 'I think so.'
- She also stated she would be more comfortable sitting on a different type of case, like a bank robbery.
Procedural Posture:
- During voir dire in the trial court, defense counsel moved to excuse Prospective Juror Number 4 for cause.
- The prosecutor opposed the challenge, and the trial court denied the motion.
- Defense counsel used a peremptory challenge to excuse the juror and subsequently exhausted all of his peremptory challenges.
- Following trial, the defendant was convicted of assault.
- The defendant, as appellant, appealed to the Appellate Division, the state's intermediate appellate court.
- A divided Appellate Division reversed the conviction, holding the challenge for cause should have been granted.
- The People, as appellant, were granted leave to appeal to the New York Court of Appeals, the state's highest court.
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Issue:
Does a trial court commit reversible error by denying a challenge for cause when a prospective juror expresses serious doubt about her ability to be impartial due to her personal background and is not asked to provide an unequivocal, personal assurance that she can be fair?
Opinions:
Majority - Chief Judge Kaye
Yes. The trial court's denial of the challenge for cause constitutes reversible error because when a juror's statements cast serious doubt on their ability to be impartial, the juror must be excused unless they provide a personal, unequivocal assurance of impartiality. Here, Prospective Juror Number 4's statements that she had a 'problem' with the case due to her extensive studies on domestic violence raised a serious doubt about her impartiality. The trial court failed to obtain a personal, unequivocal assurance from her that she could set aside her potential bias and render a verdict based solely on the evidence. A general, collective acknowledgment by the entire jury panel that they would follow the law was insufficient to cure the specific doubts raised by this individual juror. While the court also considered the potential for the juror to act as an unsworn expert, the primary error was the failure to address the stated impartiality issue directly and adequately.
Analysis:
This decision reinforces the stringent requirements for ensuring jury impartiality under New York law. It clarifies that a trial judge has an affirmative duty to conduct a specific inquiry when a potential juror raises doubts about their own fairness. The ruling establishes that a generic, panel-wide question is not a legally sufficient substitute for a personal, unequivocal assurance from the juror in question. This precedent places a heavy burden on trial courts to err on the side of excusing potentially biased jurors to protect a defendant's right to a fair trial, particularly when the defendant ultimately exhausts their peremptory challenges.
