State v. Watts

Summary

The Maine Supreme Judicial Court vacated an order granting Donald Watts III a new trial based on alleged juror misconduct and bias. The court held that the juror’s voir dire answers and post-verdict conduct provided an insufficient basis to impeach the verdict, particularly under the restrictions of Maine Rule of Evidence 606(b), and remanded for reinstatement of the convictions.

Holdings

1. The evidence provided an insufficient basis to impeach the jury verdict or find the juror biased in a manner warranting a new trial. A juror's prior consensual but uncomfortable sexual experience, the juror's discussion of that experience during deliberations, and the juror's post-verdict congratulatory call did not establish the type of dishonest answer or bias necessary to overturn the verdict.
2. Although serious allegations of juror bias based on dishonesty or inaccuracy in answering voir dire questions may justify a cautious post-trial inquiry, the inquiry in this case did not produce a sufficient basis to impeach the verdict.

Questions Presented

1. Whether the trial court had a sufficient basis to grant a new trial based on alleged juror dishonesty or inaccuracy in answering voir dire questions and alleged juror bias.
2. Whether the post-trial inquiry into the jurors' statements and conduct was permissible under M.R. Evid. 606(b).

Disposition

vacated