Tracie Easler v. State of Indiana

Summary

The Indiana Supreme Court held that a trial court must conduct a hearing when, after jury selection but before the jury is sworn, a party presents relevant information arising outside ordinary voir dire that indicates a juror may be biased. Juror 4's note disclosing that a family member had been killed by a drunk driver met that standard, and the trial court abused its discretion by refusing to investigate. Because assessing the juror's subjective bias after substantial time had passed would be unreliable and could create juror-harassment concerns, the court ordered a new trial rather than an evidentiary hearing.