People v. Hernandez-Delgado, No. H047257, 2020 WL 2092477 (Cal. Ct. App. May 1, 2020).
Categories: good cause to obtain juror identifying information, Cal. Civ. Proc. Code § 237, juror and investigator, juror interview, juror comments, Record on Appeal, juror impartiality, and racial bias.
Make sure you read this case carefully, study the lesson handout, review the issue and summary, and complete all required steps in this lesson, and every lesson in this course, before you take the final exam.
What standard is used to establish good cause to justify unsealing juror identifying information in support of a reasonable belief that jury misconduct occurred?
Defendant was convicted of first-degree murder and the jury found true gang and firearm allegations. A defense investigator spoke with Juror 4 who indicated that a female Hispanic juror mentioned that the fact that defendant was from El Salvador made her feel he was “more guilty” because “so many murders come from El Salvador.”
Defendant moved for a new trial supported by the transcript of Juror 4’s interview. The trial court denied that motion and the Sixth District Court of Appeals affirmed the denial, finding that the defendant did not demonstrate that he was prejudiced by the juror misconduct.
Six months after the Court of Appeals affirmed the judgment, defendant filed a petition with the trial court to unseal juror identifying information based on Juror 4’s statements to the defense investigator, asserting that good cause existed to disclose juror information because “a fellow juror may have relied on racial stereotypes in reaching a verdict.” The trial court denied the petition finding that good cause was not established, and defendant appealed.
Review the Useful Points of Law here: