State v. Chin
Annotate this CaseAfter a jury trial, Defendant was found guilty of theft of the proceeds of sale of the home of an individual for whom she was acting as a caregiver, changing the name of ownership of two joint accounts, and taking $8,000 from the joint account to pay off Chin’s car. Defendant filed a motion for a new trial, arguing that the actions of a jury foreperson in communicating with a main defense witness about possible employment was highly prejudicial. The circuit court denied the motion, concluding that the nature of the alleged deprivation did not rise to the level of being substantially prejudicial. The intermediate court of appeals (ICA) affirmed. The Supreme Court vacated the judgment on appeal and the judgment of conviction and sentence, holding (1) in this case, the circuit court was required to investigate the circumstances surrounding the nontrivial communication between the defense witness and the juror; and (2) because the circuit court did not conduct such an investigation, it could not be said that Defendant’s fundamental right to a fair trial by an impartial jury was not compromised. Remanded for a new trial.
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