In Re Maurice Boyette on Habeas Corpus

Summary

The court discharged its order to show cause and denied habeas corpus relief on claims that juror Ary concealed information during voir dire and that jurors considered extraneous information during penalty deliberations. It held that Ary's nondisclosures, although extensive and sometimes unreasonable, were credited as honest mistakes or failures of recollection and did not establish a substantial likelihood of actual bias. The court also held that two jurors committed misconduct by watching American Me during deliberations, but the record rebutted the resulting presumption of prejudice because the film was not inherently prejudicial and was not shown likely to have affected their verdict. Justice Corrigan, joined by Justice Liu, would have reversed the death verdict and ordered a new penalty phase because the movie likely influenced the two jurors.