Green v. State
A juror in a felon-in-possession trial admitted she Googled the defendant during deliberations and learned he had multiple prior felony convictions, then shared this with other jurors, violating the court's explicit instruction not to conduct outside research. The Fourth DCA held the trial court abused its discretion denying a mistrial because the State failed to show no reasonable possibility the misconduct affected the verdict, distinguishing the case from Key (mere improper discussion, no extrinsic evidence) and aligning it with Tapanes (extrinsic research on a relevant issue shared with the jury).
Key facts
- Defendant was tried for felon in possession of a firearm; the trial court explicitly instructed jurors not to conduct outside research.
- During deliberations, a juror Googled the defendant, discovered detailed information about his prior felony convictions, and shared this information with other jurors.
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Why it matters
This decision reinforces and applies the Tapanes framework for evaluating juror-misconduct mistrial motions, particularly in the age of smartphone research during deliberations, and clarifies that even brief independent… — full analysis with a trial
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