State v. Berhe

YU, J

¶1 This case addresses the standards and procedures that apply when trial courts must determine whether an evidentiary hearing is necessary on a motion for a new trial based on allegations that jury deliberations were tainted by racial bias. We recognize that when allegations of juror misconduct arise after the verdict, trial courts have discretion to determine whether an evidentiary hearing is necessary. However, there are limits to that discretion, particularly in cases of alleged racial bias that deprives a defendant of his or her constitutional right to a. fair trial by an impartial…