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Law School Case Brief

Lyons v. United States - 606 A.2d 1354

Rule:

A trial court’s failure to grant a mistrial motion because of prejudice that prevented a party from exposing possible juror bias and selecting an impartial jury by the use of peremptory challenges is an error that requires reversal.

Facts:

Defendants were convicted of a murder for hire committed in the course of a cocaine-selling operation. One defendant was convicted for first-degree murder, assault with a dangerous weapon (ADW), and conspiracy to distribute cocaine; while a codefendant was convicted for second-degree murder, ADW, conspiracy, and carrying a pistol without a license. Defendants appealed their convictions from the Superior Court of the District of Columbia.

Issue:

Did the prosecutor's failure to name a potential government witness on the first day of voir dire, when the juror who knew the witness was chosen, prejudice appellants by preventing them from exposing possible juror bias and selecting an impartial jury by the use of peremptory challenges?

Answer:

Yes.

Conclusion:

The court reversed defendants' convictions for first-degree murder while armed, assault with a dangerous weapon (ADW), conspiracy to distribute cocaine, second-degree murder, ADW, conspiracy, and carrying a pistol without a license and remanded the case for a new trial. The court reversed defendants' convictions on grounds that the prosecution's failure to identify one of its witnesses during jury selection violated defendant's U.S. Const. amend. VI right to an impartial jury. As such, the court remanded the case for a new trial. The court concluded the prosecutor's failure to name a detective as a potential government witness on the first day of voir dire, when the juror who knew the detective was chosen, prejudiced defendants by preventing them from exposing possible juror bias and selecting an impartial jury by the use of peremptory challenges. As such, the superior court erred in denying defendants' motion for a mistrial. The court held the superior court did not err in admitting the victim's dying declaration and found sufficient evidence to sustain the convictions against the codefendant.

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