Knox v. State, 29 A.3d 217

Knox was charged with three counts of issuing a bad check over $1,000 and was convicted by a jury.
Juror No. 8 was later found to be a victim in a pending criminal trial represented by the Attorney General's Office.
Voir dire did not reveal Juror No. 8's status as a crime victim, and the trial judge did not inquire about juror bias related to that status.
After Knox's conviction, the State disclosed Juror No. 8's connection to the AG's Office and the judge withdrew from the pending case after learning of the connection.
Knox moved for a new trial on bias grounds; the deposition of Juror No. 8 was conducted outside the courtroom
The trial judge denied the new-trial motion; Knox appealed seeking reversal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror bias due to victim status in pending case	Knox argues juror bias invalidated impartiality.	State contends juror could be impartial; no clear bias shown.	Yes; Juror No. 8 biased, requiring reversal.
Sufficiency of inquiry into juror bias	Knox asserts post-trial inquiry was inadequate; deposition alone insufficient.	State contends deposition sufficed and no plain error occurred.	Yes; inadequate inquiry constitutes plain error and requires new trial.

Mobley v. State, 559 So. 2d 1201 (Fla. Dist.Ct. App. 1990) (juror bias when victim is involved with prosecutor's office)
Commonwealth v. Frye, 909 A.2d 853 (Pa. Super. Ct. 2006) (relationship perceptions of prosecutors may affect bias)
Banther v. State, 823 A.2d 467 (Del. 2003) (juror bias undermines confidence in judicial system)
Jackson v. State, 374 A.2d 1 (Del. 1977) (juror impartiality essential to judicial process)
Wainwright v. State, 504 A.2d 1096 (Del. 1986) (plain error standard for prejudicial trial errors)
Baker v. State, 906 A.2d 139 (Del. 2006) (facially egregious misconduct can warrant reversal under plain error)
Hall v. State, 12 A.3d 1123 (Del. 2010) (juror impartiality and integrity of the process)