State v. Villeda
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The Supreme Court of the State of Oregon reviewed a case involving a defendant convicted of two domestic violence offenses, who appealed his convictions on the grounds that the trial court had erred in refusing to dismiss a prospective juror for actual bias. The prospective juror had expressed during jury selection that her close friends' experiences of sexual assault might influence her judgment. The trial court denied the defendant's request to excuse the juror, who was later dismissed by the defendant using a peremptory challenge.
On appeal, the Court of Appeals agreed with the defendant, holding that the trial court had abused its discretion in denying the defendant's for-cause challenge and that the error was prejudicial because it resulted in the loss of a peremptory challenge. The Supreme Court of the State of Oregon agreed with the Court of Appeals that the trial court had abused its discretion in denying the defendant's for-cause challenge. However, the Supreme Court held that the error did not prejudice the defendant in respect to a substantial right, as required for reversal under ORS 131.035.
The Supreme Court reasoned that the error did not interfere with the defendant's right to a fair trial before impartial jurors, and the error's impact on how the defendant used his peremptory challenges did not prejudice him in respect to a substantial right. Therefore, the Supreme Court reversed the decision of the Court of Appeals and affirmed the judgment of the trial court.
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