Does a juror's professional relationship with a prosecutor require a new trial? State v. Riddle Explained

In State v. Riddle, the Utah Court of Appeals addressed whether an undisclosed professional relationship between a juror and a prosecutor requires a new trial, even when the prosecutor did not participate in the case.

Background and Facts
Three days after Riddle’s jury trial concluded, defense counsel discovered that one of the jurors was the personal accountant for Kane County Attorney Robert Van Dyke. Importantly, Van Dyke had not participated in Riddle’s trial, which was handled by a deputy county attorney. During voir dire, jurors were asked about relationships with trial counsel, parties, and witnesses, but not about relationships with other prosecutors in the office.

Key Legal Issues
Riddle moved to set aside the jury verdict, arguing the undisclosed relationship violated his right to a fair and impartial jury. He acknowledged no evidence of actual bias but contended the relationship created an appearance of impropriety requiring reversal under theories of implied bias.

Court’s Analysis and Holding
The Court of Appeals applied an abuse of discretion standard to review the trial court’s denial of the new trial motion. The court emphasized that Utah law requires proof of actual bias to warrant a new trial based on juror partiality. While acknowledging the questionable viability of implied bias doctrine after Smith v. Phillips, the court found even that standard was not met. The professional accountant-client relationship, without more, did not suggest the juror would be unable to render an impartial verdict, particularly in a small community where such relationships are common.

Practice Implications
This decision reinforces that mere professional relationships between jurors and prosecutorial offices, standing alone, are insufficient to demonstrate bias requiring reversal. However, practitioners should ensure voir dire questions encompass relationships with all members of the prosecuting office, not just trial counsel, to avoid post-trial complications.