Last week, the California Appellate Court in a lengthy opinion (116 pages) overturned the murder conviction of Michael Pizarro (People v. Pizarro). This is the third time that Mr. Pizarro has had his sentence overturned by the appellate court. In this latest instance, the appellate court overturned the verdict because a juror conducted his own online research. Specifically, the juror learned that Pizarro had not only been convicted in a prior trial, but had also testified.
The trial court deemed the juror's action gross misconduct but not sufficient to overturn the verdict because of overwhelming evidence of Pizarro's guilt. The appellate court saw it differently stating that:
We sympathize with the trial judge who, having presided over two jury trials and a prolonged Kelly hearing amid two appeals, was called upon to make the difficult decision of whether to grant yet another new trial in a case that was then almost 20 years old." [However,] the juror's misconduct in disobeying the court's repeated admonitions and in investigating the case on his own made a mockery of the trial process and prejudiced defendant. We view that juror's behavior in this case as criminal."
Here are the reasons offered by this specific juror for why he violated the court's rules on researching the case. The juror's rational not only demonstrates the importance of simplifying evidence but also serves as a cautionary tale for attorneys and judges.
[he] was lost. And that was really [his] reasoning to try and find to know where [he] was within the case.
felt that [he] wanted to do what was right for [defendant‟s] case and understand what was going on within the case. So that was the reason why [he] had pulled up some information, which turned out to be the very thick PDF file [the prior appellate opinion], to understand how the series of events had happened.
just wanted to understand the timeline[ and] the series of events of the case so [he could] understand so [he could] be on top of stuff while [he was] listening .…