California Court of Appeal

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People v. Bryant, B219277

Conviction of second degree robbery is affirmed over claims that the trial court committed prejudicial error in denying the motion for new trial, based on allegations of jury misconduct, without holding an evidentiary hearing involving inquiry of the jurors. In light of the policy in favor of upholding the integrity of jury verdicts, and the complimentary rule that jury misconduct may warrant a new trial when shown by sworn juror affidavits, a new trial may not be granted in the absence of sworn juror affidavits establishing misconduct.

Appellate Information

  • Decided 01/24/2011
  • Published 01/24/2011

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  • California Court of Appeal

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