Manning v. State
Annotate this CaseAfter a jury trial, Defendant was convicted of burglary, battery with intent to commit a crime with a victim sixty years of age or older, and robbery with a victim sixty years of age or older. During jury deliberations, the jury gave the court a note indicating that it was deadlocked. The jury was instructed to come back the next day and continue deliberating. The court failed to inform the parties of the note until the next day after the jury returned its verdict. Defendant appealed, arguing that the district court’s failure to notify and seek input from the parties after receiving the jury’s note that it was deadlocked constituted constitutional error. The Supreme Court affirmed, holding (1) the district court violated Defendant’s due process rights by responding to the note from the jury without notifying the parties or counsel; but (2) the error was harmless beyond a reasonable doubt.
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