Fields v. Jordan, No. 17-5065 (6th Cir. 2022)
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In August, 1993, Fields, having spent the day drinking alcohol and smoking marijuana, got into a fight with Burton. Burton lived in a duplex owned by Horton. That night, Burton found that she was locked outside. Fields appeared, with a knife, and broke a window in the duplex. Both Fields and Burton fled before police arrived, having been called by a neighbor. Officers found Fields in Horton’s residence, a block away, in possession of Horton’s jewelry, saying that he had killed Horton, who was dead in her bedroom. At his second trial, the prosecution argued that Fields broke into Horton’s residence through a storm window, murdered her in the bedroom, and started burglarizing the residence shortly before police arrived. To test the plausibility of that theory, the jury conducted an experiment using a flat-tipped knife submitted into evidence to remove a cabinet door in the jury room (in place of the storm window). Satisfied with the outcome, the jurors convicted Fields of intentional murder and sentenced him to death.
The Sixth Circuit granted Fields conditional habeas corpus relief. The jury improperly considered extrinsic evidence in violation of the Fifth and Sixth Amendments. Given the centrality of the issue, the inherently prejudicial nature of the experiment, and the lack of overwhelming evidence of guilt, the jury experiment had a “substantial and injurious effect or influence in determining the jury’s verdict.”
The court issued a subsequent related opinion or order on February 22, 2023.
The court issued a subsequent related opinion or order on November 3, 2023.
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