Uranga v. State
2010 Tex. Crim. App. LEXIS 1565
| Tex. Crim. App. | 2010Background
- Appellant Uranga convicted of felony possession of methamphetamine (>1 g, <4 g).
- Punishment phase included evidence of prior and unadjudicated offenses, including an extraneous incident where Uranga damaged a juror's lawn.
- During video playback of the chase, a juror learned the damage involved his own yard; the court questioned him outside the jury and admonished him.
- Defense feared personal bias and requested mistrial; the court denied the mistrial motion.
- Appellant challenged the denial on the grounds of implied bias and improper handling of potential bias at punishment.
- appellate courts affirmed the trial court’s ruling; the Texas Court of Criminal Appeals granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does implied bias apply here? | Uranga argues implied bias should apply due to juror victim status. | Uranga contends the doctrine is applicable and mandates mistrial. | Implied bias does not apply. |
| Was the mistrial denial an abuse of discretion? | Court should have declared mistrial given juror bias risks. | Trial court properly weighed actual bias; admonitions suffice. | No abuse of discretion; hearing on actual bias adequate; mistrial not required. |
Key Cases Cited
- Smith v. Phillips, 455 U.S. 209 (1982) (due process allows post-trial bias inquiry; does not automatically require implied bias relief)
- Morales v. State, 253 S.W.3d 686 (Tex.Crim.App.2008) (acknowledges implied bias doctrine without expressly adopting it; discusses juror employment and voir dire)
- Franklin v. State, 138 S.W.3d 351 (Tex.Crim.App.2004) (juror with relationships disclosed after trial; discusses harm standard for mistrial denial)
- Jones v. State, 982 S.W.2d 386 (Tex.Crim.App.1998) (impartial-jury safeguards cross-referenced with Texas constitutional provisions)
- McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984) (recognized issue of implied bias in certain circumstances; separate from due-process inquiry)
- Smith v. Phillips (footnotes cited), 455 U.S. 209 (1982) (discussion of remedy for juror partiality via actual bias hearing)
- U.S. v. Burr, United States v. Burr, 25 F. Cas. 49 (1807) (historical basis for impartial jury concept (cited in discussion))