People v. Williams
21 P.3d 1209, 25 Cal. 4th 441, 106 Cal. Rptr. 2d 295 (2001)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A trial court has the authority under Penal Code section 1089 to discharge a juror who is unable to perform their duty, which includes situations where a juror expressly refuses to follow the court's instructions on the law due to a personal disagreement with that law.
Facts:
- Defendant Arasheik Wesley Williams, age 18, and his girlfriend, Jennifer B., age 16, engaged in sexual intercourse on December 31, 1994.
- Williams testified that the intercourse was consensual.
- Jennifer B. testified that Williams forced her to engage in intercourse by threatening her with knives.
- Williams was charged with forcible rape, with unlawful sexual intercourse (statutory rape) being a lesser included offense.
- During closing arguments, defense counsel told the jury, 'A jury may, at times, afford a higher justice by refusing to enforce harsh laws.'
Procedural Posture:
- Arasheik Wesley Williams was tried before a jury in a California superior court (trial court).
- During deliberations, the jury foreperson informed the court that Juror No. 10 refused to follow the instructions regarding unlawful sexual intercourse.
- The trial court questioned Juror No. 10, who confirmed he would not follow the law on that charge, and discharged him over the defendant's objection, replacing him with an alternate.
- The reconstituted jury convicted Williams of unlawful sexual intercourse with a minor, among other charges.
- Williams (appellant) appealed the conviction to the California Court of Appeal (intermediate appellate court), arguing the juror was improperly discharged.
- The Court of Appeal affirmed the trial court's judgment.
- The California Supreme Court (the state's highest court) granted review of the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court have the authority to discharge a deliberating juror who explicitly states an unwillingness to follow the court's instructions on a specific charge because the juror personally believes the underlying law is wrong?
Opinions:
Majority - George, C. J.
Yes. A trial court has the authority to discharge a juror who refuses to follow the court's legal instructions. While a jury may possess the practical power to nullify the law through an unreviewable acquittal, jurors have no right to do so; their duty is to apply the law as stated by the court to the facts. A juror who openly states an intention to disregard the court's instructions because of a moral or personal disagreement with the law is 'unable to perform his duty' within the meaning of Penal Code section 1089, establishing good cause for dismissal. This power is necessary to uphold the rule of law and prevent verdicts based on whim, prejudice, or anarchy rather than on the equal application of settled legal principles.
Concurring - Kennard, J.
Yes. While a juror who refuses to follow the law should be discharged, trial courts must exercise extreme caution when investigating such allegations to protect the secrecy of jury deliberations. A court's inquiry should be narrowly limited to determining whether the juror is willing to abide by their oath, without probing into the juror's reasoning, thought processes, or how they are voting. In this case, the trial court's questioning was overly broad and risked improperly intruding upon the sanctity of the deliberative process, though the ultimate decision to discharge was correct.
Concurring - Werdegar, J.
Yes. A juror's inability or unwillingness to perform their duties must be shown to a 'demonstrable reality,' a standard higher than mere substantial evidence. This high standard ensures that a juror is not removed for simply disagreeing with other jurors about the facts of the case. In this instance, the record clearly shows to a demonstrable reality that Juror No. 10 was unwilling to perform his duty because he explicitly stated his refusal to follow the law, thus his discharge was proper.
Analysis:
This decision firmly establishes in California law that there is no right to jury nullification. It draws a critical distinction between a jury's unreviewable power to acquit against the evidence (a byproduct of procedural safeguards like double jeopardy) and a juror's legal duty to follow the court's instructions. By empowering trial courts to dismiss jurors who openly intend to nullify, the ruling reinforces the judiciary's role in ensuring verdicts are based on law and fact, not individual jurors' moral judgments. This precedent significantly curtails attempts to actively use nullification as a defense strategy and clarifies the grounds for juror removal during deliberations.
Unlock the full brief for People v. Williams