Commonwealth v. Buzzard

9 Pa. D. & C. 419, 1927 Pa. Dist. & Cnty. Dec. LEXIS 65
CourtNorthampton County Court of Quarter Sessions
DecidedJanuary 10, 1927
DocketNo. 2; No. 81
StatusPublished

This text of 9 Pa. D. & C. 419 (Commonwealth v. Buzzard) is published on Counsel Stack Legal Research, covering Northampton County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Buzzard, 9 Pa. D. & C. 419, 1927 Pa. Dist. & Cnty. Dec. LEXIS 65 (Pa. Super. Ct. 1927).

Opinion

Stewart, P. J.,

After a hotly contested trial which lasted for almost two weeks, the jury brought in a verdict of “guilty.” A motion in arrest of judgment was made, and at the same time a motion for a new trial was made and reasons were filed in support thereof. The subject-matter of the motion in arrest of judgment and for a new trial is identical. After examination of all the reasons, we were satisfied that the motions could not [420]*420be granted for the first ánd second reasons, nor for the fourth and fifth reasons, all of which matters had been fully argued at the ’‘time of trial, but we felt that the third reason should receive investigation, and, therefore, granted a rule to show cause, at the same time filing an opinion for the guidance of the parties. Depositions were taken and argument was had fully upon the subjects herein discussed. At the close of the defendant’s depositions, the record shows that defendant’s counsel objected to any depositions being taken by the Commonwealth. This objection was not pressed on the argument, and we do not think that it is a good one. In an investigation of this character, no technical objection should prevail, and we have found that matters really important from the defendant’s point of view were brought out by the Commonwealth. The third reason is that the verdict was vitiated by the misconduct of interested witnesses and parties, as well as by statements and declarations of jurors, &c. Then follow the sub-sections to which we shall hereafter refer. Those allegations are extremely serious ones, and, if proved, demand that a new trial be granted the defendant. The law on the subject is not as well defined in Pennsylvania as it is upon most other subjects, for the reason that the granting of a new trial is a matter of discretion, and few opinions of the Supreme and Superior Courts are to be found, compared with the number in other states, although we have the benefit of a number of very late decisions which we shall refer to. It would be impossible to review the decisions of the lower courts, although we have examined all that have been cited to us. The best statement of the general subject that we have found is contained in 12 Cyc., 717, as follows:

“1. In General. All of the courts, no doubt, agree that any misconduct on the part of the jurors in a criminal case which was prejudicial to the defendant, or any such misconduct on the part of the judge, officer in charge or outsiders, improperly influencing the jurors, not caused nor waived by defendant, is ground for setting aside a conviction and granting a new trial. On the other hand, as a general rule, a new trial will not be granted where it clearly appears that defendant has not been injured or prejudiced by the misconduct.
“2. As a rule, if the party asking for a new trial participated in the misconduct, or, knowing of it, failed to call the attention of the court promptly to it and move for the dismissal of the jury, he cannot urge it as ground for a new trial.
“3. Beyond this, however, the. cases are conflicting. Some hold that if such misconduct might have been prejudicial to defendant, prejudice will be presumed, particularly in capital cases, and that a new trial must be granted, unless this presumption is rebutted by affirmatively showing that there was in fact no prejudice. A few cases hold that, in capital eases at least, prejudice will be conclusively presumed and a new trial granted if there may have been prejudice. Others hold generally that prejudice will not be presumed, at least unless a probability of prejudice appears, and that a new trial will not be granted unless defendant affirmatively shows that he has been prejudiced.
“4. It may be laid down as a general rule that if the jurors in a criminal case are permitted to converse or communicate with outsiders, or if they so converse or communicate without permission, or if they are permitted by the judge or officer in charge to be or remain where they may hear remarks or conversations of outsiders, or to be otherwise subjected to improper influence, and defendant is thereby prejudiced, a new trial must be granted; but a new trial will not be granted if defendant has not been prejudiced by the irregularity. Some of the cases hold that defendant must show that he was prejudiced, [421]*421while others hold that prejudice will be presumed, unless the contrary appears or is shown by the prosecution. The rules above stated apply to conversations between the jurors and the prosecuting attorney, or judge, or witnesses. It has been said that the test to determine whether a conversation by a juror with outsiders is ground for a new trial is whether the remarks indicate that he is an unfit person to discharge the duties of a juror.” A quotation taken from the opinion of Chief Justice Allen in Nichols v. Nichols, 136 Mass. 256, on page 260, is often quoted as containing the rule to follow. It is as follows: “In the various emergencies which are liable to occur in the course of a protracted trial, irregularities must occur sometimes. While the court will always seek to guard against them, and especially to keep the jury as far as possible from all influences which can cast a suspicion upon the integrity of their verdict, it nevertheless ought not to be swift to grant a new trial on account of irregularities not attended with any intentional wrong, and where it is made satisfactorily to appear that the party complaining has not and could not have sustained any injury from them.” In Com. v. Filer, 249 Pa. 171, on page 178, Mr. Justice Elkin said: “It is strongly urged for appellant that the court below erred in overruling the motion for a new trial. Ordinarily, this is a question within the sound discretion of the trial judge, and the refusal of such a motion does not constitute reversible error unless there has been a clear abuse in the exercise of that discretion.” Again he said: “The affidavit of the officer in charge of the jury in substance states that during the time he had taken the jurors out for exercise in the morning, they had stopped at a point near the railroad and viewed a location which the defendant had mentioned in his testimony, and that this was done in the absence of appellant and his counsel. The affidavits of the jurors being excluded, the facts stated in the affidavit of the officer were the only ones brought to the attention of the trial judge, not included in the record proper, in passing upon the motion for a new trial. There was nothing in this affidavit to indicate that the defendant was injured or prejudiced by anything the jurors did at that time, and the general rule is that a new trial will not be granted unless it appears that the alleged misconduct was prejudicial to the rights of the accused: 12 Cyc., 717. Such matters rest largely in the discretion of the trial judge: Alexander v. Com., 105 Pa. 1; Com. v. Manfredi, 162 Pa. 144.” In the very helpful and carefully prepared book by Chief Justice Moschzisker, “Trial by Jury,” on page 306, he said: “Sect. 421. I cite the Deutsch case as illustrative of the modern judicial tendency not to interfere with the course of trial in criminal cases, on complaints of misconduct, unless it satisfactorily appears the defendant himself was responsible for the matters complained of, or that they will materially harm him; a tendency which is now sufficiently established to call for notice. Sect. 422.

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Related

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129 A. 453 (Supreme Court of Pennsylvania, 1925)
Alexander v. Commonwealth
105 Pa. 1 (Supreme Court of Pennsylvania, 1884)
Commonwealth v. Manfredi
29 A. 404 (Supreme Court of Pennsylvania, 1894)
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59 A. 272 (Supreme Court of Pennsylvania, 1904)
Commonwealth v. Hoover
75 A. 1023 (Supreme Court of Pennsylvania, 1910)
Commonwealth v. Filer
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Commonwealth v. Tilly
33 Pa. Super. 35 (Superior Court of Pennsylvania, 1907)
Greason v. Cumberland Railway Co.
54 Pa. Super. 595 (Superior Court of Pennsylvania, 1913)
Commonwealth v. Deutsch
72 Pa. Super. 298 (Superior Court of Pennsylvania, 1919)
Goodright v. M'Causland
1 Yeates 372 (Supreme Court of Pennsylvania, 1794)
Nichols v. Nichols
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Bluebook (online)
9 Pa. D. & C. 419, 1927 Pa. Dist. & Cnty. Dec. LEXIS 65, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-buzzard-paqtrsessnortha-1927.