Wahl v. State
Annotate this CaseAfter a jury trial, Defendants, a married couple, were each convicted of involuntary manslaughter. After they were sentenced, Defendants filed a motion to correct error seeking a mistrial based on one juror’s affidavit describing the conduct of an alternate juror during the jury’s deliberations. The trial court denied the motion. The Court of Appeals affirmed the convictions. The Supreme Court granted transfer, consolidated the cases, and reversed the convictions, holding (1) the juror’s affidavit established that the alternate juror’s participation in jury deliberations was an external influence that pertained to the case, which showings resulted in a presumption of prejudice to Defendants; and (2) the State did not rebut the presumption by showing that the jury was nonetheless impartial, and therefore, a new trial is required. Remanded.
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