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Richard Massey v. State Delaware

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eBook details

  • Title: Richard Massey v. State Delaware
  • Author : Supreme Court of Delaware
  • Release Date : January 28, 1988
  • Genre: Law,Books,Professional & Technical,
  • Pages : * pages
  • Size : 64 KB

Description

HORSEY, Justice: This post-conviction relief appeal concerns an effort to impeach a jury verdict for alleged juror misconduct more than nine
years after the verdict was rendered. The alleged misconduct involves one juror's purported use of alcohol and drugs during
the course of defendant's murder trial. After several post-conviction relief motions and appeals, the Superior Court held
an evidentiary hearing on the issue. Finding insufficient evidence of juror misconduct to impeach defendant's verdict, the
Court denied defendant relief and defendant appealed. The issues on appeal are: (1) the appropriate burden of proof for a
defendant to successfully challenge a jury verdict based on juror misconduct; and (2) whether defendant met that burden. We
hold that to impeach a verdict based on juror misconduct, a defendant must establish actual prejudice unless defendant can
show that the circumstances surrounding the misconduct were so egregious and inherently prejudicial so as to support a presumption
of prejudice to defendant. We find that this defendant has failed to meet that burden; therefore, we affirm.


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