Parker v. Gladden

Background

The defendant was convicted of second-degree murder and later filed a state post-conviction petition. At a hearing the trial court found that a court bailiff, who had been with a sequestered jury for eight days, made two outside remarks to jurors — "Oh that wicked fellow, he is guilty" and "If there is anything wrong the Supreme Court will correct it" — and that those comments were overheard by jurors or an alternate. The trial court found the communications prejudicial; the Oregon Supreme Court disagreed and reversed.

Reasoning

The Supreme Court reviewed whether those private statements by a court officer deprived the defendant of the right to an impartial jury. The Court held the comments were governed by the Sixth Amendment right to trial by an impartial jury, as applied to the States through the Fourteenth Amendment, and stressed that outside statements not subject to cross-examination can unfairly influence jurors. The majority noted that the bailiff’s official role, lengthy sequestering, 26 hours of deliberation, and at least one juror’s admission of influence supported the trial court’s finding. The Court reversed the state decision and ordered relief.

Real world impact

Criminal defendants gain stronger protection against outside influence from court officers and others who interact with juries. Trial courts must treat communications by court officers as highly suspect where they can reach jurors, and similar misconduct can justify new trials when it meaningfully taints jury impartiality. This decision resolves the federal constitutional question against the State.

Dissents or concurrances

Justice Harlan dissented, arguing federal constitutional standards should not automatically overturn verdicts absent a strong showing of actual prejudice and warning against encouraging post-trial harassment of jurors.