Fields v. Saunders
2012 OK 17
| Okla. | 2012Background
- This case concerns the right to an impartial jury under Article 2, Section 19 of the Oklahoma Constitution.
- Plaintiffs allege a juror concealed bias against them during voir dire and disclosed bias after verdict.
- The biased juror allegedly disliked African Americans and doubted plaintiffs' right to recover under the burden of proof.
- The juror provided inaccurate information about prior misdemeanor convictions on the voir dire questionnaire.
- Plaintiffs learned of the bias after verdict, prompting a motion for new trial and an evidentiary hearing where the trial court assessed credibility and impact.
- The Oklahoma Supreme Court reversed and remanded the judgment as to certain defendants, emphasizing de novo review for constitutional issues involving juror bias.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether juror bias violated the right to jury trial | Fields argued bias denied fair trial and requires new trial. | Saunders/Reilly argued no prejudice established or bias not proven to affect verdict. | Yes; bias violated the right to an impartial jury. |
| What standard of review applies to post-verdict juror-bias challenges | De novo review appropriate for constitutional dimension. | Traditional abuse-of-discretion standard should apply. | De novo review applies for constitutional juror-bias issues. |
| Role of post-verdict statements and testimony in deciding bias | Post-verdict disclosure by juror shows disqualifying bias and justifies new trial. | Post-verdict statements should not undermine verdict absent clear prejudice. | Post-verdict disclosure can establish bias and support new trial where circumstances are comparable. |
Key Cases Cited
- Parrish v. Lilly, 1993 OK 80 (1993) (impartiality required; post-verdict bias grounds reviewed de novo)
- Bickell v. State, 41 Okla. Crim. 35, 270 P. 88 (1928) (prejudice shown by juror conduct beyond assurances of impartiality)
- Jackson v. General Finance Corp., 208 Okla. 44, 253 P.2d 166 (1953) (duty to preserve purity of jury trial)
- Keller v. State, 651 P.2d 1339 (1982) (public policy against post-verdict juror impeachment)
- Capshaw v. Gulf Ins. Co., 107 P.3d 595 (2005) (standard of appellate review for trial rulings)
- Willoughby v. City of Oklahoma City, 706 P.2d 883 (1985) (interpretation of rules similar to Rule 606(b) standard)
- U.S. v. Benally, 546 F.3d 1230 (2008) (racial bias not a per se harsher category for juror impeachment)