State v. Wallace
110 So. 3d 1199, 12 La.App. 5 Cir. 594, 2013 WL 646402 (2013)
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Rule of Law:
Under Louisiana's jury shield law, La. C.E. art. 606(B), juror testimony is inadmissible to impeach a verdict based on statements or beliefs shared among jurors during deliberations, as these are considered internal matters and do not qualify as an improper 'outside influence' or 'extraneous prejudicial information.'
Facts:
- Robert Goertz and his wife Jeanette Goertz were driving when a pickup truck, driven by Wallace, approached at high speed, swerved around them, cut them off, and ran a red light.
- Mrs. Goertz recorded the truck's license plate number.
- After the truck made an abrupt U-turn, Wallace pointed a gun out of his driver-side window in the direction of the Goertzes' vehicle as he passed them.
- Mr. Goertz, an off-duty state trooper, followed Wallace's truck to report its location to police, which led to a series of evasive maneuvers by Wallace, including threatening a head-on collision.
- Wallace later followed the Goertzes' vehicle into a supermarket parking lot before they drove to a police station.
- Upon being stopped by police, Wallace was cooperative and informed the officer that a firearm was in his vehicle.
- Police located a Ruger semi-automatic pistol and two loaded magazines in the truck's center console.
Procedural Posture:
- Wallace was charged in a Louisiana trial court with two counts of possession of a firearm during the commission of a crime of violence.
- Wallace filed a pre-trial motion to quash the charges on double jeopardy grounds, which the trial court denied.
- The intermediate appellate court denied Wallace's pre-trial supervisory writ application on the double jeopardy issue.
- The Louisiana Supreme Court also denied writs on the pre-trial double jeopardy issue.
- Following a jury trial, Wallace was convicted of the lesser offense of attempted possession of a firearm during the commission of a crime of violence on count one and was acquitted on count two.
- Wallace filed a post-verdict motion for acquittal and a motion to adduce testimony from a juror, both of which the trial court denied.
- Wallace appealed the trial court's judgment to the Court of Appeal of Louisiana, Fifth Circuit.
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Issue:
Does a trial court err by refusing to hear testimony from a juror regarding improper considerations during deliberations, such as other jurors' comments and mistaken beliefs about the defendant's criminal history, under Louisiana's jury shield law?
Opinions:
Majority - Windhorst, J.
No, the trial court did not err in denying the motion to adduce testimony from a juror. Louisiana's jury shield law, La. C.E. art. 606(B), generally prohibits inquiry into the jury's deliberations to preserve the finality of verdicts and the confidentiality of juror discussions. The law provides narrow exceptions for 'outside influence' or 'extraneous prejudicial information' improperly brought to the jury's attention. Here, the defendant alleged that jurors discussed their mistaken belief that he was a convicted felon and recognized him from crime reports. The court reasoned that these were comments and beliefs originating from within the jury itself, not from an outside source. Therefore, these discussions constitute the very internal deliberations that the jury shield law is designed to protect from post-verdict scrutiny. The allegations do not fall under the exceptions, so the juror's testimony was properly excluded.
Analysis:
This decision strongly reinforces the finality of jury verdicts and the sanctity of jury deliberations under Louisiana law. It strictly interprets the exceptions to the jury shield rule, clarifying that misinformation or improper reasoning originating from within the jury room does not qualify as an 'outside influence' or 'extraneous information.' This holding makes it exceedingly difficult to challenge a verdict based on the content of juror discussions, prioritizing the policy of protecting jurors from post-trial harassment and ensuring candor during deliberations over correcting potential juror error. The case demonstrates that for a verdict to be impeached, the prejudicial influence must come from a source external to the jury itself.
