Freddy Flonnory v. State of Delaware

Summary

The Delaware Supreme Court reviewed Freddy Flonnory's direct appeal from convictions and a death sentence for murder and related offenses. The court held that improper extraneous communications and prejudicial information reached the jury, creating presumptive prejudice and violating Flonnory's right to a fair trial before an impartial jury. The judgments of the Superior Court were reversed and the case was remanded for a new trial.

Holdings

1. Communication of highly prejudicial, improper, and inadmissible information about Flonnory's alleged prior murder involvement to jurors outside the courtroom violated his right to a fair trial before an impartial jury under the Sixth Amendment, as applied through the Fourteenth Amendment, and Article I, § 7 of the Delaware Constitution.
2. When a defendant proves a reasonable probability of juror taint arising from egregious circumstances that are inherently prejudicial, prejudice is presumed and the defendant need not prove actual prejudice.
3. Actual prejudice was independently established when a juror testified that the improperly communicated information about Flonnory's alleged prior murder involvement affected her vote to convict him of first-degree murder.
4. Once the guilt phase had concluded and the court learned that the jury had deliberated with inherently prejudicial extraneous information, manifest necessity required a mistrial; the trial court erred by denying Flonnory's mistrial motion and proceeding to the penalty phase.

Questions Presented

1. Whether extraneous, highly prejudicial information that Flonnory had previously been accused of murder was improperly communicated to the jury outside the courtroom and violated his constitutional right to a fair trial before an impartial jury.
2. Whether the circumstances established a presumption of prejudice under Delaware's egregious-circumstances test for juror taint.
3. Whether the sworn testimony that the extraneous information affected one juror's vote established actual prejudice.
4. Whether the trial court was required to declare a mistrial after learning that the jury had deliberated with the prejudicial information.

Disposition

reversed_and_remanded