Idaho v. Garcia-Ongay
Annotate this CaseTomas Daniel Garcia-Ongay appealed his conviction for lewd conduct with a minor under the age of sixteen. After Garcia-Ongay’s conviction, the Jury Commissioner informed the district court of his concerns that a juror in the trial had expressed clear racial bias when he was summoned for jury duty. In light of this information, Garcia-Ongay moved for a new trial and requested that the district court grant permission for him to investigate whether racial animus tainted the jury’s deliberations. The district court denied the motion and the accompanying request. On appeal, Garcia-Ongay contended the district court abused its discretion in denying his request for further investigation, arguing that the United States Supreme Court’s holding in Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (2017), permitted such an inquiry. To this, the Idaho Supreme Court agreed: the district court abused its discretion in denying Garcia-Ongay’s request for post-trial juror contact because good cause existed to suggest that racial animus could have tainted the jury’s deliberations. Accordingly, the case was remanded to allow Garcia-Ongay to interview Juror #9 and, in the discretion of the district court, contact the other jurors to investigate whether racial prejudice infected their deliberations.
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