Colorado’s Court of Appeals has ruled that claims surrounding a juror’s anti-police remarks during a civil trial do not warrant a new trial, reaffirming the limitations on what jurors can be questioned about post-deliberations. Typically, jurors are protected from testifying about their internal discussions, although exceptions exist for instances of improper outside influence or severe bias. The appellate panel clarified that the constitutional exception recognized by the U.S. Supreme Court, which addresses extreme biases affecting trial integrity, does not extend to anti-police sentiments.
In a decision rendered on May 1, a three-judge panel determined that while racial bias remains a well-documented issue in juror conduct, anti-police bias does not present the same systemic concerns. Judge Elizabeth L. Harris, writing for the court, noted that statements likening police officers to individuals who protect their own do not rise to the level of bias that undermines a jury’s constitutional assignment.
The case arose from an incident in Denver in December 2019, when Officer John Logue accidentally injured plaintiff Quinessa Caylao-Do with his vehicle. She subsequently sued both Logue and the city for negligence. A jury ruled in favor of Caylao-Do during a 2022 trial, awarding her damages. Following this ruling, the defense sought a new trial, alleging that one juror, referred to as Juror S, exhibited clear bias against police officers.
Juror S allegedly made various inflammatory statements that included negative remarks about police conduct and suggested the jury should assist Caylao-Do in obtaining damages from Denver. The juror’s comments prompted concerns from other jurors, who later expressed discontent about discussions during deliberations. However, in rejecting the defense’s motions, the trial judge emphasized the importance of allowing jurors to engage in robust discussions, stating that their final verdict reflected a collective decision.
The defense’s argument invoked a previous Supreme Court ruling that permitted inquiries into jury deliberations when a juror made racially charged comments during a trial. However, during the appeals hearing, the court expressed caution about broadening the constitutional exemption to include biases related to a juror’s occupation. Judge Katharine E. Lum questioned the precedent that bias against specific professions could be operationalized in legal challenges against jury decisions.
Assistant City Attorney Honor K. Moore countered that the unique climate surrounding law enforcement merits careful consideration of the statements made by Juror S. Yet, Judge Harris challenged the conclusions made about the juror’s comments, asserting they did not amount to anti-police bias but rather reflected perceptions rooted in the evidence presented in the trial.
The court concluded that its decision aligns with longstanding legal principles prohibiting jurors’ discussions from being scrutinized after a verdict has been reached. It reiterated that the recognized bias exceptions in the legal framework only apply in clear and compelling circumstances, such as racial bias.
In its ruling, the appellate panel also rebuffed a secondary argument from the defense regarding the exclusion of a Black juror from the jury pool. The defense maintained that this juror, referred to as Juror W, shared attributes with Caylao-Do that would lead to an inherent bias. The trial judge previously determined that the challenge was likely motivated by racial factors, reinforcing the constitutional protections around exclusion.
Ultimately, the Court of Appeals upheld the ruling of the lower court, affirming that the defense lacked sufficient evidence to demonstrate Juror W’s participation compromised the integrity of the jury’s deliberations. The case remains a pertinent example of the complexities involved in navigating bias within juror conduct during trials.
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