State of Idaho v. Rodriguez (Idaho Supreme Court 2023)
Idaho v. Rodriguez is a recent Idaho Supreme Court decision involving a murder trial following a 25-year unsolved case in Cassia County. In 1995 a young girl was found murdered. For twenty-five years law enforcement attempted to locate the assailant. Eventually, the FBI became involved and three key witnesses to the case were identified and interviewed.
By this time much of the physical evidence of was gone. There was no murder weapon and the State had little to go on. To prove its case, the State relied on witness testimony from persons currently incarcerated, as well as the autopsy of the deceased young girl. A jury trial ensued.
After the trial and deliberations, the Jury found the defendant, Rodriguez, guilty of the 1995 murder. Defense was astonished and hired a private investigator to speak with jurors willing to share their thoughts and experiences. At that time, it came to Defense’s attention that a juror was sleeping. A motion for a new trial was filed and the district court held an evidentiary to determine whether juror misconduct occurred.
The district court determined that there was no juror misconduct, and that the juror had not been sleeping during significant portions of the trial, and Rodriguez was not prejudiced by the jurors’ actions of lowering his head and closing his eyes. Rodriguez appealed the district courts decision.
In order to be granted a new trial based on juror misconduct, a person must first prove by clear and convincing evidence that juror mis conduct actually occurred. The Idaho Supreme Court issued a decision and explained that if a party observes what amounts to juror misconduct, it should be raised at trial, not afterwards. And in a case like this, where it is discovered afterwards it, then juror misconduct must be proved by clear and convincing evidence.
Moral of the Case: If you are in trial and you observe a juror nodding off, speak up or you may not preserve that issue for an appeal. And if you happen to be a juror, try to remain alert, that way you aren’t hauled into court on claims of misconduct.
Read the Full Case Opinion Here: https://isc.idaho.gov/opinions/49266.pdf
Hope you enjoyed this case brief!
Warmly,
Juniper Cooper-Grivas
Seems the testimony of the juror themselves admitted that they fell asleep at all should have been enough to get a new one. Especially on a murder trial. :)