Supreme Court of Delaware

Brice M. Hall, Defendant Below-Appellant v. State of Delaware, Plaintiff Below-Appellee

August 13, 20102010 Del. LEXIS 398

Summary

The court held that employment as a correctional officer, standing alone, does not automatically disqualify a person from jury service or establish juror bias. But the juror here directly supervised Hall on the same prison tier, repeatedly observed his cell, handled inmate mail, and had an institutional interest in preventing violence there, creating an impermissible probability of unfairness. Because a biased juror constitutes a structural defect, the court reversed the conviction and remanded for a new trial; the court did not reach Hall's separate challenge to the adequacy of voir dire.