Friday, January 31, 2025
Illinois Judge Grants New Trial Based on Juror's Research Into Defendant's Criminal Record
According to an article on WJBD,
Marion County Resident Circuit Court Judge Mark Stedelin has overturned the murder conviction of Ricky Norwood of Centralia and ordered a new trial. Stedelin made the decision following an investigation into jury misconduct during the trial held in October 2023.
Specifically,
State’s Attorney Tim Hudspeth says the judge began looking into jury misconduct when a friend had overheard conversation about a jury doing their own investigation and learning Norwood was serving time in federal prison at the time of the trial on unrelated charges. The jury then reportedly told others on the panel. Jury members are not allowed to consider past convictions when hearing a trial.
This would be covered by Illinois Rule of Evidence 606(b), which provides that
Upon an inquiry into the validity of a verdict or indictment, a juror may not testify as to any matter or statement occurring during the course of the jury’s deliberations or to the effect of anything upon that or any other juror’s mind or emotions as influencing the juror to assent to or dissent from the verdict or indictment or concerning the juror’s mental processes in connection therewith. But a juror may testify (1) whether any extraneous prejudicial information was improperly brought to the jury’s attention, (2) whether any outside influence was improperly brought to bear upon any juror, or (3) whether there was a mistake in entering the verdict onto the verdict form. A juror’s affidavit or evidence of any statement by the juror may not be received concerning a matter about which the juror would be precluded from testifying.
Evidence of a criminal defendant's prior criminal record is classic "extraneous prejudicial information" that provides a proper predicate for jury impeachment because it is exactly the type of propensity character evidence that the rules of evidence deems inadmissible.
-CM
https://lawprofessors.typepad.com/evidenceprof/2025/01/according-to-an-article-on-wjbd-marion-county-resident-circuit-court-judge-mark-stedelin-has-overturned-the-murder-convic.html