Godoy v. Spearman, No. 13-56024 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit reversed the denial of habeas relief to petitioner, who was convicted of second degree murder. Petitioner claimed that there was improper outside influence on the jury. The en banc court held that the state appellate court's decision was contrary to clearly established Supreme Court law in Mattox v. United States, 146 U.S. 140, 149, and Remmer v. United States, 347 U.S. 227, 229. In denying relief because petitioner's evidence did not prove prejudice, the state court acted contrary to Mattox and Remmer; it was error to rely on the very same statement from Juror 10's declaration both to raise the presumption of prejudice and to rebut it; and the state court denied petitioner a hearing on prejudice under the wrong legal standard. Accordingly, the en banc court remanded with instructions to hold a hearing to determine the circumstances of Juror 10's misconduct, the impact on the jury, and whether it was prejudicial.
Court Description: Habeas Corpus. The en banc court reversed the district court’s judgment denying a habeas corpus petition in which Enrique Anthony Godoy, who was convicted of second-degree murder, claimed improper outside influence on the jury. The en banc court held that the California Court of Appeal – which acknowledged juror misconduct and a presumption of prejudice, but concluded that the presumption was rebutted and refused to hold an evidentiary hearing – acted contrary to clearly established law: (1) by never requiring the state to rebut the presumption of prejudice, as required by Mattox v. United States, 146 U.S. 140 (1892), and Remmer v. United States, 347 U.S. 227, 229 (1954); (2) by relying on the same statement from a juror’s declaration both to raise the presumption of prejudice and to rebut it; and (3) by requiring Godoy to show a “strong possibility” of prejudice in order to have an evidentiary hearing, contrary to the Remmer requirement of a hearing whenever, as here, the presumption attaches but the prejudicial effect of the improper contact is unclear from the record. GODOY V. SPEARMAN 3 The en banc court remanded with instructions that the district court hold a hearing to determine the circumstances of a juror’s misconduct, the impact upon the jury, and whether or not it was prejudicial.
This opinion or order relates to an opinion or order originally issued on August 25, 2016.
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