Does a defendant have to meet with a juror to determine whether a defendant has made a sufficient showing of misconduct on a request to disclose juror information?

California, United States of America


The following excerpt is from People v. Marroquin, B259682 (Cal. App. 2016):

In People v. Carrasco, supra, 163 Cal.App.4th 978, the inquiry took place during the polling of the jury at the end of trial, and it was prompted by the juror's expression of doubt about her vote. The case does not stand for the proposition that the trial court must meet with a juror to determine whether a defendant has made a sufficient showing of misconduct on a request to disclose juror information. Moreover, here, the juror's note to the trial court stated that the juror did not want to change the verdict. The court reasonably interpreted that statement to mean the juror had no reasonable doubt about the verdict. The court, also reasonably, concluded that the juror's note did not show juror misconduct, but indicated the juror's need for "affirmance and validation." There was no need to conduct further inquiry, and the court did not abuse its discretion is denying appellant's motion to disclose the juror's personal information.

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