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Home / Case Digests / Court of Appeals — ‘Buford’: People v. Mejias; People v. Rodriguez

Court of Appeals — ‘Buford’: People v. Mejias; People v. Rodriguez

New York State Court of Appeals

‘Buford’

Unqualified Juror — Note Seeking More Information

People v. Mejias; People v. Rodriguez
Nos. 67 & 68
Judge Pigott

Background: At issue was whether the trial court erred in failing to conduct an inquiry of a sworn juror who had written a note to the court seeking additional information, before the jury was charged.

Ruling: The Court of Appeals held that the trial court did not violate People v. Buford, 69 NY2d 290 (1987). In Buford, the court held that before a court can dismiss a juror as grossly unqualified, it must first question the juror individually in camera in the presence of the defendant and the attorneys. In this appeal, the note’s contents did not cast doubt on the juror’s impartiality or that the juror had committed any misconduct.

No 67: John R. Lewis for the appellant; Timothy C. Stone for the respondent; No 68: Robert Moore for the appellant; Timothy C. Stone for the respondent