State v. Henderson
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In this case, the defendant, Lawrence Lee Henderson, was convicted of home invasion after a jury trial. During the trial, the defendant contracted COVID-19, resulting in a 25-day delay in jury deliberations. When the deliberations resumed, the jury found the defendant guilty of home invasion but not guilty of other charges and lesser included offenses.
The defendant appealed, claiming that the court should reverse his conviction of home invasion or grant him a new trial on that charge because the jury’s verdicts of guilty of home invasion and not guilty of a lesser included offense were legally inconsistent. He also claimed that the trial court abused its discretion by failing to declare a mistrial when he contracted COVID-19, which resulted in the delay in jury deliberations.
The court upheld the trial court’s decision, holding that legally inconsistent verdicts are unreviewable on appeal, following its precedent in State v. Arroyo, which was consistent with United States Supreme Court precedent and that of the majority of other jurisdictions. In terms of the COVID-19 delay, the court found that the trial court did not abuse its discretion in denying the defendant's motion for a mistrial, as the delay was unavoidable due to the pandemic, and the defendant failed to demonstrate actual prejudice from the delay.
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