State v. Coaxum

Summary

The South Carolina Supreme Court reversed the Court of Appeals and upheld William Coaxum's convictions for armed robbery and possession of a firearm during the commission of a violent crime. The court held that a trial judge may, in the exercise of discretion, replace a juror midtrial for an unintentional nondisclosure during voir dire when the concealed information would have been material to a party's exercise of peremptory challenges. Because the jury remained impartial after the substitution and Coaxum failed to show prejudicial abuse of discretion, a new trial was not warranted.

Holdings

1. When a juror's nondisclosure during voir dire is unintentional, the trial court has discretion to proceed with the jury as constituted, replace the juror with an alternate, or declare a mistrial. The court must determine whether the concealed information would have supported a challenge for cause or been a material factor in exercising a peremptory challenge.
2. The trial court did not abuse its discretion by removing Juror #7 and replacing her with the alternate juror, because it conducted a thorough inquiry and determined that the undisclosed relationship would have been a material factor in the State's exercise of its peremptory challenges.
3. State v. Burgess improperly read prior South Carolina precedent as prohibiting removal of a juror whenever the juror's nondisclosure was unintentional, without considering whether the information was material to a party's exercise of a peremptory challenge.

Questions Presented

1. Whether the trial court abused its discretion by removing Juror #7 during trial for her unintentional failure to disclose a relationship with a member of the defendant's family during voir dire.
2. What showing is required when a juror unintentionally fails to disclose information that might have affected a party's exercise of peremptory challenges.

Disposition

reversed