State of Tennessee v. William Darelle Smith
418 S.W.3d 38
| Tenn. | 2013Background
- Victim Zurisaday Villanueva was found shot to death; William Darelle Smith was indicted and tried for first-degree murder based on forensic evidence and statements by witnesses.
- During trial, the court warned jurors not to discuss the case; the jury was not sequestered and final instructions did not specifically forbid electronic communications.
- After closing arguments and during jury deliberations, the trial judge received an email from the State’s medical examiner, Dr. Adele Lewis, quoting a Facebook message from juror Glenn Scott Mitchell praising her testimony and noting he was on the jury.
- The trial court informed counsel of the email but declined defense counsel’s request to question the juror or the witness; the jury returned a guilty verdict and the court denied a new-trial motion without holding a hearing.
- The Court of Criminal Appeals affirmed; the Tennessee Supreme Court granted permission to appeal, held the trial court erred in not conducting an immediate evidentiary hearing, vacated and remanded for a hearing to determine prejudice and possible juror disqualification.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Smith) | Held |
|---|---|---|---|
| Whether the trial court must hold a hearing after learning a juror communicated with a State witness during trial | The court acted within discretion; mere interaction did not show prejudice requiring inquiry | The Facebook contact created a rebuttable presumption of prejudice and required an immediate hearing to probe scope and effect | Trial court erred: reliable evidence of an extra-judicial communication triggered a rebuttable presumption of prejudice and required an immediate evidentiary hearing (reviewed de novo) |
| Whether the email from Dr. Lewis was admissible to trigger inquiry | The email was not a basis for broad inquiry beyond what judge learned | The email was competent evidence of communication and admissible (not probing juror mental processes) | The email provided reliable, admissible evidence that an extra-judicial communication occurred and warranted inquiry |
| Standard for burden of proof once communication is shown | The State need not justify absence of prejudice absent strong showing of impact | Upon showing of communication (and especially possible extraneous influence), burden shifts to State to explain or prove harmlessness beyond a reasonable doubt | When jurors are not sequestered, there must be proof that extraneous prejudicial information or improper influence reached jurors; if so, burden shifts to State to rebut presumption of prejudice |
| Appropriate remedy when trial court fails to hold hearing | Denial of new trial was within discretion without further inquiry | Failure to hold hearing deprived Smith of right to fair trial; remand required for hearing or grant new trial | Remedy is vacatur and remand for an evidentiary hearing; if a fair hearing is impossible or prejudice shown, grant new trial |
Key Cases Cited
- Remmer v. United States, 347 U.S. 227 (1954) (trial court must investigate allegations of outside influence on jurors)
- Smith v. Phillips, 455 U.S. 209 (1982) (impracticability of shielding jurors from all outside contacts; courts must guard against influences)
- State v. Blackwell, 664 S.W.2d 686 (Tenn. 1984) (extra-judicial juror contact that introduces extraneous prejudicial information warrants new trial)
- United States v. Fumo, 655 F.3d 288 (3d Cir. 2011) (social media increases risk that juror online comments will import extraneous information or influence)
- State v. Bondurant, 4 S.W.3d 662 (Tenn. 1999) (trial courts must preserve integrity of jury process; juror accountability and sequestration principles)