Is there good cause for disclosure of juror information to support a motion for new trial based on juror misconduct?

California, United States of America


The following excerpt is from People v. Perkins, F060071 (Cal. App. 2012):

Good cause for disclosure of juror information to support a motion for new trial based on juror misconduct is "a sufficient showing to support a reasonable belief that jury misconduct occurred." (People v. Rhodes (1989) 212 Cal.App.3d 541, 552; People v. Jefflo (1998) 63 Cal.App.4th 1314, 1322.) There is no good cause where allegations of

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jury misconduct are speculative, conclusory, or unsupported, or the alleged misconduct is not "of such a character as is likely to have influenced the verdict improperly." (Evid. Code, 1150, subd. (a); see Rhodes, supra, at p. 552.) We review the denial of a petition for disclosure for an abuse of discretion. (People v. Jones (1998) 17 Cal.4th 279, 317.)

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