People v. Flack

9 N.Y.S. 279, 8 N.Y. Crim. 31, 24 Abb. N. Cas. 444, 1890 N.Y. Misc. LEXIS 128
CourtCourt Of Oyer And Terminer New York
DecidedMarch 31, 1890
StatusPublished
Cited by1 cases

This text of 9 N.Y.S. 279 (People v. Flack) is published on Counsel Stack Legal Research, covering Court Of Oyer And Terminer New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Flack, 9 N.Y.S. 279, 8 N.Y. Crim. 31, 24 Abb. N. Cas. 444, 1890 N.Y. Misc. LEXIS 128 (N.Y. Ct. App. 1890).

Opinion

Barrett, J.

Under section 463 of the Code of Criminal Procedure, a new trial can only be granted in the eases provided in section 465. The latter section confers upon the court power to grant such new trial when a verdict has been rendered against the defendant, by which his substantial rights have been prejudiced, in the cases specified in the seven subdivisions which follow. These seven subdivisions need not be quoted in extenso, for the reason that the incident upon which the present application is founded has no relation to any of these subdivisions, except, possibly, the fourth. There is no pretense [280]*280of any misconduct upon the part of the jury. Consequently, the third subdivision is inapplicable. The sole question is whether the verdict is vitiated by the misconduct of a stranger, and the only provision under which the discussion on this head is admissible is that embodied in the fourth subdivision. The latter reads as follows: “When the verdict has been decided by lot, or by any means other than a fair expression of opinion on the part of all the jurors. ” The burden of establishing prejudice to his substantial rights, and the fact that the verdict was reached by means other than that referred to in the statute, is upon the defendant. In the present instance, the stranger had no communication whatever with the jury. Their deliberations had proceeded for nearly three hours without even a suspicion of his presence. Upon his discovery, he was brought forthwith before the court, and his misconduct became the subject of brief and incomplete consideration. The hour was late, and the jury had, prior to the discovery, asked for instructions which it was important they should receive before midnight, as the next day was Sunday. It was ascertained that the intruder was a newspaper reporter named Choate. The investigation was necessarily somewhat hurried, and before it was fully terminated the court proceded to instruct the jury upon the subject of their previous inquiry. In this brief investigation, however, the reporter’s stenographic notes, taken in the jury-room, were produced and delivered to the court. He was then required to promise not to reproduce from memory, or to publish, what he had heard. This promise he did not give. He hesitated, and expressed reluctance. Without waiting for an affirmative refusal, the court temporarily dropped the subject, and proceeded to instruct the jury, as already stated. The defendants were present. Their counsel were also present, and took part both in the investigation, and in what followed with regard to the instructions called for. They excepted to the instructions given, and requested instructions in another form. Thereupon the jury again retired. Ho objection was made by the defendants or by their counsel to the further consideration of the case, nor to the rendition of the verdict.

The point upon which the new trial is asked is substantially this: that some of the jurors may have been influenced by the knowledge of Choate’s professional character, and by the belief, resulting from that knowledge, and from his refusal to promise secrecy, that their attitude in the jury-room would be disclosed to the public, and that thus they might be subjected to criticism, or unfavorable comment'. There is no evidence that any juror was in fact influenced by this incident, or that he gave his adhesion to the verdict because of such consideration. On the contrary, we have a very strong affidavit from all the jurors to the effect that they were not influenced by this incident in the slightest degree, and that they decided the case solely upon the evidence, and the law applicable thereto. Indeed, the affidavit goes so far as to state that the verdict had in fact been agreed upon before the discovery, subject (to quote the expression used in the affidavit of the jurors) “to the definition of law” which had been requested from the court. After the most diligent search, I have been unable to find any case in this state where prejudice to the defendant, as matter of law, has ever been inferred from such circumstances as these, or from circumstances in any way cognate. The rule before the Code was that a verdict would not be set aside unless it clearly appeared that the irregularity or improper conduct had actually influenced the verdict; and it was well settled that, while the affidavits of jurors might be received to support their verdict, they would not be received to impeach or vitiate it. Dana v. Tucker, 4 Johns. 487. And their affidavits to support the verdict have been received, not only as to facts which came under their observation, but as to the influence of such facts upon their minds. Baker v. Simmons, 29 Barb. 198. Indeed it was not until the Code Crim. Proc. § 421, that the officers or constables were absolutely forbidden by statute to speak to the jury, or to be present during their deliberations. People v. Hartung, 17 How. Pr. 88. [281]*281:Such conduct on the part of constables was always disapproved; but verdicts were repeatedly sustained notwithstanding their presence in the jury-room, and even when they had actually solicited the jury to render a verdict for one side or the other. In Taylor v. Everett, 2 How. Pr. 23, it appeared that the constable gave the foreman of the jury intelligence that a boy had been ground up in the latter’s mill, whereby the juror became so alarmed, and so desirous •of returning home, that he was induced to agree to a larger verdict than he intended. The supreme court denied a new trial; Jewett, J., stating that the affidavit of a juror could not be received to prove irregularity or misconduct on his own part, or that of his fellows, and that, rejecting the affidavits of the jurors, there was no evidence that the intelligence communicated by the constable influenced the verdict in any respect. The conclusion of the court was that, although the conduct of the constable was deserving of severe animadversion, yet the verdict could not be set aside on that ground. In People v. Carnal, 1 Parker, Crim. R. 256, it was held that a communication made to the jury, while deliberating, by the constable, to the effect that the judge said “they had nothing to do with manslaughter,” was not, in the absence of actual prejudice, sufficient to avoid the verdict. The court observed that, while any communication to a jury during their deliberation, made by •a party in whose favor the verdict was rendered, would avoid the verdict, he knew of no case where such an effect had ever been given to a communication by the losing party, or by a stranger to the controversy; and for the reason, as he supposed, that it would be giving to intermeddlers a power and control over the administration of justice that was denied even to the court. These cases were cited and approved in Baker v. Simmons, 29 Barb. 199, where the constable urged the jury to give their verdict to the prevailing party. Some of the jurors told him “to be still and mind his own business;” and they all swore that his remarks had no influence upon them, or the verdict which they gave. The verdict was sustained; Judge Mason declaring that it would be a practice rendering very insecure the verdict of the jury, if it were liable to beset aside for every such officious intermeddling of strangers to the controversy; “for the same principle,” said the learned judge, “which would set aside the verdict when the constable wrongfully interfered with the jury would also invalidate the verdict when any other person did so.” "This latter observation was referred to with approval in Hager v. Hager, 38 Barb. 102.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

N. Wagman & Co. v. Schafer Motor Freight Service, Inc.
167 Misc. 681 (City of New York Municipal Court, 1938)

Cite This Page — Counsel Stack

Bluebook (online)
9 N.Y.S. 279, 8 N.Y. Crim. 31, 24 Abb. N. Cas. 444, 1890 N.Y. Misc. LEXIS 128, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-flack-nyoytermct-1890.