State v. Dixon

Summary

The court affirmed the murder conviction, holding that the defendant did not preserve his claim concerning a special eyewitness-misidentification instruction and that the trial court had no sua sponte duty to give it under the circumstances. The court further held that the trial court acted within its discretion in investigating possible juror bias and that excluding the defendant from the in camera hearing did not violate his constitutional rights because counsel participated and the jury had already reached its verdict. The court also declined to resolve which party bears the burden of proving juror impartiality because the evidence supported the trial court's finding under either allocation.