People v. Black
Annotate this CaseAfter a jury trial, Defendant was convicted of two counts of animal cruelty. During voir dire, the trial court denied Defendant’s challenges to two prospective jurors on incompetence grounds, after which Defendant used two of his allotted peremptory challenges to remove the same jurors. Defendant subsequently exhausted his peremptory challenges and unsuccessfully requested that the trial court grant him extra peremptory challenges to remove other prospective jurors he deemed to be objectionable. On appeal, Defendant claimed he was entitled to reversal of the trial court’s judgment because one of the jurors he objected to sat on his case. The Supreme Court affirmed Defendant’s conviction, holding (1) Defendant cured any error that occurred when the trial court denied his for-cause challenges because those jurors were removed with Defendant’s peremptory challenges; (2) the trial court was under no obligation to grant Defendant extra peremptory challenges to remove additional, otherwise competent, jurors; and (3) because no incompetent juror who should have been dismissed for cause sat on Defendant’s case as a result of Defendant exhausting his peremptory challenges, Defendant was not entitled to reversal.
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