Loehrlein v. State
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The Supreme Court affirmed Defendant's conviction of the murder and attempted murder of his family members, holding that one of the jurors committed gross misconduct and that, under the circumstances, Defendant did not demonstrate that the misconduct probably harmed him.
After Defendant was convicted, he filed a motion to set aside the verdict based on juror misconduct, alleging that one juror, L.W., falsely answered the juror questionnaire. The juror wrote "N/A," meaning not applicable, in response to questions about the jurors past criminal history and whether she had been a victim of a crime, when those answers should have been a yes. The trial court denied Defendant's motion to set aside the verdict. The Supreme Court affirmed, holding (1) juror L.W. committed gross misconduct; but (2) despite the gross misconduct, it was unlikely that Defendant was harmed.
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