California Supreme Court
P. v. Anzalone
June 12, 2013
Summary
The court held that the trial court failed to comply with the statutory procedure requiring an acknowledgment that the jury had agreed on its verdict, but that the omission was not structural error. Because all 12 jurors were present when the verdict was read and recorded, no juror dissented, and the parties did not request polling or object, the error was subject to harmless-error review and was plainly harmless. The court also held that the defendant forfeited the statutory-procedure claim by failing to object, although it reached the merits because the issue was of statewide importance.