State of New Jersey v. Kalil Griffin
155 A.3d 8
| N.J. Super. Ct. App. Div. | 2017Background
- Griffin was convicted by jury of felony murder, first-degree robbery, and two handgun offenses in Monmouth County.
- An alternate juror reported pre-deliberation discussions among jurors despite court admonitions, with one juror vowing to ensure Griffin would not get off like the co-defendant.
- Defense filed a motion for a hearing on juror misconduct; the trial judge who presided retired, and another judge conducted a record hearing months later.
- The second judge limited inquiries to two alternate jurors; the State sought interlocutory review and the court applied de novo review to Rule 1:16-1 issues.
- The court ultimately reversed the post-verdict interviewing order, holding the allegations did not establish good cause under Rule 1:16-1, but remanded for sentencing and entry of a judgment of conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether post-verdict juror interviews were permitted under Rule 1:16-1. | Griffin contends good cause exists to interview discharged jurors. | Griffin argues policy favors protecting jury secrecy; interrogations after verdict undermine deliberations. | No good cause; post-verdict interviews not warranted. |
| Whether Loftin and LaFera carve out exceptions to the secrecy rule for pre-deliberation statements. | Lofton/LaFera support evaluating potential bias affecting verdict. | These exceptions apply; there was potential pre-deliberation bias. | LaFera controls; no sufficient proof of bias; Loftin distinguishable. |
| Whether there was permissible inquiry based on outside influence or potential racial bias. | Allegations show possible outside influence and bias warrant investigation. | Allegations are insufficient to show juror bias or impact on verdict. | Insufficient to justify post-verdict interrogation. |
| Whether the court’s procedural handling (limited to non-deliberating jurors) affects the analysis. | Restriction does not negate Rule 1:16-1 concerns. | Limitation preserves secrecy and avoids intruding into deliberations. | Procedure insufficient to establish good cause; reversed and remanded. |
| Whether the case should be remanded for sentencing and judgment notwithstanding the delay. | Remand is necessary to finalize judgment. | No judgment yet; remedy appropriate is remand for sentencing. | Reversed order, remanded for sentencing and entry of judgment of conviction. |
Key Cases Cited
- State v. Loftin, 191 N.J. 172 (2007) (premature deliberation evidence insufficient to overturn verdict; capital context)
- State v. LaFera, 42 N.J. 97 (1964) (deliberation bias not revealed post-verdict; cannot overturn verdict)
- State v. Koedatich, 112 N.J. 225 (1988) (two exceptions to post-verdict inquiries for good cause)
- Athorn, 46 N.J. 247 (1966) (post-verdict juror examination disfavored; strong public policy against interference)
- Davis v. Husain, 220 N.J. 270 (2014) (post-verdict questioning is extraordinary; require strong showing of harm)
- R.D., 169 N.J. 551 (2001) (trial court must inquire into juror taint before verdict; post-verdict limits)
- State v. Harris, 181 N.J. 391 (2004) (high bar for good cause under Rule 1:16-1; reaffirmed approach)
- State v. DiFrisco, 174 N.J. 195 (2002) (affidavits from counsel about juror matters insufficient to justify post-verdict inquiry)
- Loftin (additional citation note), See State v. Loftin, 191 N.J. 172 (2007) (referenced for distinctions between pre- and post-verdict considerations)