Non-Disclosure by a Juror Example Cases In California

In People v. Price (1991) 1 Cal.4th 324, involving the defendant's challenge to removal of a juror, the juror had failed to disclose he had served a sentence for assault with a dangerous weapon and was paroled in California where he was supervised by a prosecution witness in the proceeding at issue, and also that he was thereafter in 1976 charged with assault with a deadly weapon, which was dismissed against the then district attorney who was the trial judge in the proceeding at issue. (Price, 1 Cal.4th at pp. 399-400.) People v. Morris (1991) 53 Cal.3d 152 involved a juror's failure to disclose convictions for misdemeanor offenses including drunk driving, and the fact he had been charged of obstructing and resisting an officer. (People v. Morris, 53 Cal.3d at pp. 183-184.) Indeed, the appellate court in Morris observed that apart from the concealment, the prosecutor had advised the court he had personally prosecuted that juror for some of the charges, permitting an inference of bias. (Id. at p. 184.)