In re ManriquezAnnotate this Case
After issuing an order to show cause with respect to Petitioner habeas claim that prejudicial juror misconduct occurred when a juror did not timely disclose a history of childhood abuse, the Supreme Court discharged the order to show cause and held that Petitioner was not entitled to relief.
Petitioner was convicted of four counts of first degree murder and was sentenced to death. Petitioner then filed this amended habeas corpus petition alleging that the jury foreperson had committed misconduct by concealing that he was abused as a child. The Supreme Court issued an order to show cause and ordered a reference hearing directing a referee to answer four questions. After an evidentiary hearing, the referee found that there was no prejudicial juror misconduct because the juror’s nondisclosure was neither intentional nor deliberate and that juror was not biased against Petitioner.
The Supreme Court agreed generally with the referee’s findings and held that Petitioner failed to establish that he was entitled to habeas corpus relief on his claim of prejudicial juror misconduct.