State v. Roman, 320 Conn. 400

Ruben Roman was convicted in 2000 of murder, assault, illegal firearm possession, and risk of injury to a child; at sentencing he raised an allegation of juror misconduct but the trial court denied a continuance and did not immediately inquire.
This Court (Roman) remanded in 2003 for an inquiry into the juror-misconduct allegation; an evidentiary hearing was not held until 2013 after a decade-long scheduling delay.
At the 2013 postremand hearing the defendant presented testimony from a bus rider (Mary Eason) who overheard passengers mention the case and possibly contact with a juror, and testimony from the full original jury and two surviving alternate jurors about alleged out-of-court and in-court communications.
Alternate jurors P.M. and M.M. admitted to exchanging looks and limited nonverbal comments during trial but denied discussing case substance with each other or with regular jurors; regular jurors uniformly denied outside discussions or use of the bus.
The trial court (Judge Dewey) found no evidence that any juror leaked deliberative information or that alternates influenced the regular jurors, and denied a new trial; the defendant also claimed the ten-year delay violated due process.
The Connecticut Supreme Court affirmed: no prejudicial juror misconduct proved, and the delay—while long—did not deprive Roman of due process because he could fully present his claim and suffered no demonstrable prejudice.

Issue	Plaintiff's Argument (Roman)	Defendant's Argument (State)	Held
1. Did alleged juror communications (bus conversation and alternates' in-court comments) constitute prejudicial juror misconduct requiring a new trial?	Eason’s bus testimony showed a juror spoke to passengers about the case; alternates’ eye-rolling and comments infected the jury and influenced regular jurors.	The bus statements were ambiguous and could come from media; alternates’ conduct was limited, involved no substantive discussion, and did not reach regular jurors.	No abuse of discretion: defendant failed to prove actual prejudice; testimony did not show a juror leaked deliberative information nor that alternates influenced deliberating jurors.
2. Did the roughly ten‑year delay in scheduling the postremand inquiry violate Roman’s due process / fair-trial rights?	The delay undermined the integrity of the inquiry and deprived Roman of a timely remedy.	Delay had mixed causes (defense efforts to locate witnesses, court scheduling difficulties, unforeseeable events); Roman could still present witnesses and suffered no prejudice.	No due process violation: although delay was extraordinary, Barker factors show defendant’s own lack of diligence and absence of prejudice weigh against relief.

State v. Brown, 235 Conn. 502 (Conn. 1995) (jury right to impartial panel under state and federal constitutions)
State v. Rhodes, 248 Conn. 39 (Conn. 1999) (defendant bears burden to prove actual prejudice when court not at fault for juror misconduct)
State v. West, 274 Conn. 605 (Conn. 2005) (trial court has broad discretion in responding to juror-misconduct allegations)
Barker v. Wingo, 407 U.S. 514 (U.S. 1972) (four-factor balancing test for delay: length, reason, assertion, prejudice)
State v. Johnson, 288 Conn. 236 (Conn. 2008) (opportunity for misconduct is not equivalent to actual misconduct)