State v. Bunton

Summary

The Utah Court of Appeals held that the district court abused its discretion by denying the defendant’s for-cause challenge to a prospective juror who expressly stated that he could not be impartial in a child-sexual-abuse case. Because the biased juror served on the jury, the court treated the error as prejudicial, vacated the convictions, and remanded for a new trial. The court did not reach the defendant’s additional claims concerning DNA evidence, ineffective assistance of counsel, or cumulative error.

Holdings

1. The district court exceeded its discretion by denying Bunton's for-cause challenge because Juror 23 made an unsolicited, unequivocal admission that he could not give an unbiased opinion in a child-sexual-abuse case, and the subsequent questioning did not sufficiently rebut that indication of actual bias.
2. The presence of a biased juror on the empaneled jury prejudiced Bunton and required vacatur of his convictions because it denied him a fair trial and constituted structural error.
3. The court did not address Bunton's ineffective-assistance, DNA-evidence, or cumulative-error claims because the juror-bias error independently required a new trial.

Questions Presented

1. Whether the district court abused its discretion by denying Bunton's challenge for cause to Juror 23 after the juror expressly stated that he did not think he could give an unbiased opinion in a child-sexual-abuse case.
2. Whether the seating of the allegedly biased juror prejudiced Bunton and required reversal or vacatur of his convictions.
3. Whether the court should address Bunton's separate claims concerning ineffective assistance of counsel, DNA evidence, and cumulative error.

Disposition

vacated