State v. Costello

Summary

The Minnesota Supreme Court held that jurors may not question witnesses in a criminal trial. The court concluded that juror questioning threatens juror neutrality, may encourage premature formation of opinions, and can affect the state's burden of proof in the adversarial system. The court reversed Gerard J. Costello's convictions and remanded for a new trial.

Holdings

1. Under its supervisory power, the Minnesota Supreme Court held that no court shall permit jurors to question witnesses during a criminal trial.
2. Because Costello timely objected and the effects of juror questioning on the evidence, advocacy, and deliberations could not be quantified, the error was not subject to harmless-error analysis and Costello was entitled to a new trial.
3. The court did not reach Costello's state and federal constitutional claims because it resolved the issue under its supervisory power.

Questions Presented

1. Whether a Minnesota district court may permit jurors to question witnesses during a criminal trial.
2. Whether permitting juror questioning undermines juror neutrality and the adversarial allocation of the burden of proof.
3. Whether the preserved error required a new trial or could be deemed harmless.

Disposition

reversed_and_remanded