Spectator Misconduct Case in California
People v. Chatman (2006) 38 Cal.4th 344, involved a defendant's claim of spectator misconduct.
In that case, the defendant moved for a mistrial because the victim's mother had made several outbursts. The trial court denied the motion. (Id. at pp. 366-368.)
The Supreme Court held the trial court did not abuse its discretion in denying the mistrial motion, and the defendant was not prejudiced. (Chatman, supra, 38 Cal.4th at pp. 368-369.)
The Court also held:
"Surely, we would not say that the mother of either the victim or the accused should be excluded from the courtroom simply because she might act beyond the strictures of accepted legal deportment." Holloran reads too much into this quote, arguing "Just as Chatman's judge could not exclude the victim's mother," so too the judge here could not properly exclude Holloran's father for acting beyond the strictures of acceptable legal deportment. The "legal deportment" in Chatman did not involve talking to jurors outside of the courtroom. Moreover, our high court in Chatman did not hold the mother could not be excluded. It merely held that the trial court did not abuse its discretion in denying defendant's mistrial motion grounded on a claim of prejudice resulting from the mother's decorum inside the courtroom during trial. (Id. at pp. 369-370.)