State v. Outlaw

Summary

The court affirmed the defendant’s convictions, concluding that the trial court’s response to an apparently sleeping juror adequately addressed the potential misconduct and did not deprive him of a fair trial. The court held that admitting testimony about witness-protection arrangements was erroneous but did not produce a manifest injustice, and that any error in admitting a cooperating witness’s specific guilty pleas was harmless. The prosecutor’s reference to that witness’s guilty plea was permissible because it supported her credibility rather than criticizing the defendant for exercising his jury-trial right. Justice Ecker concurred in the judgment while finding the juror inquiry inadequate, and Justice McDonald would have ordered a new trial on the affected charges.