State v. JohnsonAnnotate this Case
The Supreme Court reversed the judgment of the district court convicting Defendant of offense of partner or family member assault, holding that the district court abused its discretion in denying Defendant’s motion to excuse a prospective juror for cause.
In this case, a prospective juror spontaneously asserted that she would have a “hard time,” a personal “problem,” and a “real problem” with requiring the State to prove an essential element of the charged offense. The Supreme Court held that where the prospective juror’s multiple spontaneous statements were consistent, clear, unequivocal, and emphatic and where the record unequivocally manifested the juror’s bias, the district court abused its discretion in denying Defendant’s motion to disqualify the prospective juror for cause. Further, the error was structural, requiring automatic reversal.