State v. Quinn, 95 N.E.3d 664

Background

Defendant James Quinn was convicted by a jury of multiple felonies (domestic violence, kidnapping, abduction, intimidation of a victim) after a two-day trial and sentenced to a total of 20 years' imprisonment.
Quinn appealed, the Second District affirmed, he filed an application to reopen on ineffective assistance grounds focused on trial court rulings during voir dire; the court granted reopening and Quinn proceeded pro se.
Quinn challenged two prospective jurors for cause during voir dire: (1) "the Locksmith" who said he tended to believe police testimony over lay witnesses because of long experience working with law enforcement; (2) a Clark County deputy who knew the prosecutors, the lead detective, and said he was "familiar with the defendant."
The trial court overruled both challenges for cause; Quinn used peremptory strikes to remove both jurors and exhausted his peremptory challenges.
Quinn argued on reopened appeal that the overruling of the two challenges forced him to exhaust peremptory strikes and therefore required reversal; he also alleged nondisclosure and prosecutorial misconduct regarding the deputy's involvement, but the court limited review to jury-selection errors.
The majority held the trial court did not abuse its discretion in denying the challenges for cause and affirmed; a concurring opinion found any juror bias harmless on the facts, and a dissent would have reversed as to both jurors.

Issues

Issue	Plaintiff's Argument (Quinn)	Defendant's Argument (State / Trial Court)	Held
Whether the trial court abused its discretion by denying a challenge for cause to the Locksmith juror who said he tended to believe police	Locksmith's statements showed an inability to be impartial and required excusal for cause; failure forced Quinn to expend a peremptory strike	Juror acknowledged presumption of innocence and burden of proof and did not say he could not be fair; trial court could credit his assurance of impartiality	Denial not an abuse of discretion; juror qualified to serve
Whether denial of a challenge for cause to a deputy sheriff juror who knew prosecutors and the defendant required reversal	Deputy's employment and familiarity with parties created bias and required excusal; nondisclosure by deputy or state is prosecutorial misconduct	On the record, deputy's answers raised only a possibility of bias; defense failed to question further to establish actual partiality; burden on movant to prove cause	Denial not an abuse of discretion because defendant did not elicit facts showing inability to be impartial
Whether error (if any) in overruling challenges was prejudicial because it forced exhaustion of peremptory strikes	Overruling forced Quinn to use peremptory strikes and thus prejudiced his rights to peremptories	Court will not reverse unless composition of jury panel may have been affected; judge's credibility calls entitled to deference	No reversible error: no showing that jury composition was affected or that challenge rulings were prejudicial

Key Cases Cited

Morgan v. Illinois, 504 U.S. 719 (U.S. 1992) (right to impartial jury and voir dire standards)
Adams v. Texas, 448 U.S. 38 (U.S. 1980) (juror views that prevent performance justify exclusion)
Wainwright v. Witt, 469 U.S. 412 (U.S. 1985) (deference to trial court's juror-bias credibility determinations)
Gray v. Mississippi, 481 U.S. 648 (U.S. 1987) (prejudice analysis focuses on potential effect on jury composition)
DePew v. State, 38 Ohio St.3d 275 (Ohio 1988) (appellate deference to trial judge on juror credibility)
State v. Broom, 40 Ohio St.3d 277 (Ohio 1988) (same principle regarding juror-bias review)
State v. Hale, 119 Ohio St.3d 118 (Ohio 2008) (no complaint when overruling challenge for cause does not force exhaustion of peremptories)
Berk v. Matthews, 53 Ohio St.3d 161 (Ohio 1990) (challenge-for-cause rulings reviewed for abuse of discretion)
Huffman v. Hair Surgeon, Inc., 19 Ohio St.3d 83 (Ohio 1985) (definition of abuse of discretion)