TROY SHERMAN NASH v. STATE OF MARYLAND
Court of Appeals, Harrell, Filed June 20, 2014,
Juror Conduct- Where the court received a note from the jury alleging impropriety where one juror stated an intent to vote guilty so that they wouldn’t have to adjourn for the weekend, no abuse of discretion to adjourn the jury immediately and have them resume deliberations after the weekend instead of declaring a mistrial.
Pretty fact specific case
Where
– There is no preexisting bias
– and juror conduct was not the type that would prejudice further proceedings
– and there was sufficient information upon which to determine the issue
There was no need for the trial court to sua sponte conduct voir dire of the juror
Dissent by McDonald+2, who believe that the juror’s stated intent to abandon their role in favor of leaving early was sufficient to require further inquiry