Lloyd v. the State
339 Ga. App. 1
| Ga. Ct. App. | 2016Background
- Marcus Lloyd was tried by jury and convicted of aggravated assault and possession of a firearm during the commission of a felony; he was acquitted on other counts and sentenced to 25 years.
- During trial the court repeatedly instructed jurors not to conduct outside research or discuss the case; the jury later asked for definitions and was recharged on justification/self-defense.
- Juror R.R. researched malice and felony murder online, spoke during a lunch break with a police officer about “stand your ground,” and later created and presented a diagram to the jury incorporating the officer’s explanation.
- The jury’s vote had been 11–1 for acquittal until after R.R.’s outside research, officer conversation, and diagram; following R.R.’s presentation the jury returned guilty verdicts on two counts.
- Lloyd moved for a new trial after other jurors reported R.R.’s misconduct; the trial court found misconduct but held it harmless; the Court of Appeals reversed, finding the state failed to overcome the presumption of prejudice.
Issues
| Issue | Lloyd's Argument | State's Argument | Held |
|---|---|---|---|
| Whether juror R.R.’s extraneous communication and outside research presumptively prejudiced the verdict | Juror engaged in unlawful extraneous research and spoke with a police officer about a central issue (self-defense), which likely changed jurors’ views and thus prejudiced the verdict | Misconduct was harmless because the officer’s explanation aligned with the court’s instructions and did not convey case facts or a prejudicial opinion | Presumption of prejudice applies in criminal cases; state failed to rebut it beyond a reasonable doubt; reversal required |
| Whether discussion with police officer was merely legal clarification or an improper outside influence | Lloyd: officer’s explanation (and R.R.’s presentation) effectively injected extraneous, prejudicial information about pursuit and ‘‘stand your ground’’ into deliberations | State: officer gave a general legal explanation consistent with the court’s charge, so no harm | Court of Appeals: officer’s explanation about pursuit and R.R.’s diagram influenced jurors on the key self-defense issue; misconduct was harmful |
| Whether juror’s internet research on malice and felony murder was prejudicial | Lloyd: juror’s independent legal research on murder definitions is extraneous information and undermines verdict reliability | State: online definitions mirrored trial materials; harmless | Court did not decide this issue because prior holding on officer communication was dispositive |
| Whether Armstrong (civil-case analysis) altered presumption of prejudice in criminal juror-misconduct claims | Lloyd: presumption of prejudice applies in criminal cases under Georgia precedent | State: attempted to rely on Armstrong to argue no presumption | Court: Armstrong is a civil-case decision and does not abrogate long-standing criminal-case presumption of prejudice |
Key Cases Cited
- Jones v. State, 258 Ga. 96 (presumption of harm from improper juror communications in criminal cases)
- Whitlock v. State, 230 Ga. 700 (same rule on juror misconduct)
- Dudley v. State, 179 Ga. App. 252 (juror misconduct and prejudice presumption)
- Simmons v. State, 291 Ga. 705 (presumption of harm; state must rebut beyond a reasonable doubt)
- Greer v. Thompson, 281 Ga. 419 (criminal juror misconduct precedent)
- Hammock v. State, 277 Ga. 612 (misconduct affecting key issue and timing of influence supports reasonable possibility of contribution to conviction)
- Chambers v. State, 321 Ga. App. 512 (noting risks where not all jurors testify)
- Armstrong v. Gynecology & Obstetrics of DeKalb, P.C., 327 Ga. App. 737 (civil-case analysis distinguishing application of presumption)