Bell v. Uribe

Overlapping claims under federal and state law may be considered adjudicated even if one is not specifically addressed by a lower court; a juror who does independent research and shares that research to be relied upon by the other jurors in violation of the judge's order acts improperly and may be dismissed.

At the trial of Terry Lee Bell and Natalie DeMola, Juror No. 7 was dismissed for misconduct. She had offered her “expert opinion on the petitioners’ mental health” and had looked up a medical definition in a dictionary, which she shared with her “fellow jurors during deliberations.” The petitioners claimed that the juror’s removal had violated their Sixth Amendment right to a fair trial. The California Court of Appeal rejected their claim. The petitioners sought habeas relief from the District Court who found that the California Court of Appeal had failed to “address the petitioners’ Sixth Amendment arguments” and had only analyzed state law. The Ninth Circuit disagreed and found that the petitioners’ state and federal claims overlapped. Thus, the panel held that the Court of Appeal had “adjudicated … the petitioners’ Sixth Amendment” claims. The petitioners argued that the California Court of Appeal’s rejection of their claim was “an unreasonable application of” federal law because the juror’s dismissal was unjustified. Jurors are ‘“neither disqualified from service based on their personal expertise nor barred from using” their experience to interpret evidence. The panel noted that the juror had violated the court order ‘“not to do any independent research”’ and she had asked the other jurors to ‘“rely on her expertise and specialized knowledge.” Thus, the panel held that her dismissal was justified and that federal law been reasonably applied. DeMola claimed that her sentence of “life without the possibility of parole” violated the Eighth Amendment because, as a juvenile, “the court was prohibited from imposing” this type of sentence. She cited Miller v. Alabama, which held that, when mandated for juveniles, her sentence violated the Eighth Amendment. The panel noted that the state’s sentencing scheme does not mandate this sentence for juveniles. DeMola’s claim was rejected. REVERSED. VACATED. REMANDED. DENIED.