State v. Paul Bedell

Summary

The New Hampshire Supreme Court held that the trial court erred by dismissing a juror for cause after trial began because the record did not establish an objective basis for finding that the juror was no longer impartial. The court affirmed the defendant’s convictions for aggravated felonious sexual assault, concluding that the error was not prejudicial because an impartial jury ultimately rendered the verdict.

Holdings

1. The trial court erred in dismissing the juror because the record did not establish an objective basis for finding that she could no longer be fair, impartial, and unbiased.
2. The erroneous dismissal did not require reversal because the defendant did not demonstrate that the jury that rendered the verdict was impartial or that he suffered prejudice.

Questions Presented

1. Whether the trial court abused its discretion by dismissing a previously seated juror for cause after the trial had begun.
2. Whether the erroneous mid-trial dismissal of the juror required reversal of the defendant's convictions despite the absence of any claim that the jury that rendered the verdict was impartial.

Disposition

affirmed