State Of Washington, V Robin Adell Lander, 49501-5

On June 26, 2014, a confidential informant purchased methamphetamine from a woman in an alley located within 1,000 feet of a school bus route stop.
A detective later identified Robin Adell Lander from a photograph as the woman who sold the methamphetamine.
The State charged Lander with delivery of a controlled substance within 1,000 feet of a school bus route stop (RCW 69.50.401, .435).
At trial (about two days), Lander contested identity; jury deliberated roughly four hours before reporting it was deadlocked.
The trial court asked the presiding juror whether there was a reasonable probability of reaching a verdict; the juror said no, but the court instructed the jury to continue deliberating.
Later the same day, the jury returned guilty verdicts (including the school-bus-stop special verdict); each juror confirmed the verdict on polling.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Lander)	Held
Whether the trial court erred by failing to declare a mistrial after the jury reported it was deadlocked	The court should be allowed to ask jurors to continue deliberating and to deny mistrial absent clear prejudice	The jury said it was deadlocked and the court should have declared a mistrial	Court held no abuse of discretion in denying mistrial given trial length, ~4 hours deliberation, and case complexity
Whether the court coerced the jury by instructing them to continue after they said they could not reach a verdict	Continued deliberation instruction was permissible and non-coercive	The instruction coerced an invalid verdict by pressuring jurors to agree	Court held instruction was not coercive; defendant failed to show a substantial possibility the verdict was improperly influenced

State v. Emery, 174 Wn.2d 741 (2012) (standard for mistrial: only where prejudice requires new trial)
State v. Burdette, 178 Wn. App. 183 (2013) (jury’s assertion of deadlock alone insufficient for mistrial)
State v. Strine, 176 Wn.2d 742 (2013) (deference to trial court’s deadlock/discretion assessment)
State v. Dykstra, 33 Wn. App. 648 (1983) (distinguishable facts regarding mistrial and re-trial)
State v. Gaines, 194 Wn. App. 892 (2016) (trial court must avoid coercive pressure on jurors)
State v. Ford, 171 Wn.2d 185 (2011) (defendant must show a reasonably substantial possibility that court action coerced verdict)