A state appeals court panel Wednesday reversed a man’s conviction for fatally stabbing a longtime friend at a Santa Monica apartment, finding that a judge should have conducted a more detailed inquiry into what a juror told his fellow panelists during deliberations about his outside research into the difference between murder and manslaughter before he was excused from the jury.
The three-justice panel from California’s 2nd District Court of Appeal ordered the case against Ryan Taylor Bright to be sent back for retrial.
Bright was convicted in December 2014 of second-degree murder for the July 11, 2012 death of Jensen Gray.
In its 12-page ruling, the appellate court panel agreed that the trial court “acted properly in immediately conducting a hearing to determine whether there was a substantial likelihood the misconduct had tainted the jury,” but found that the scope of the inquiry was “too limited.”
During the trial court’s investigation, one juror stated that the dismissed juror had not only looked up the differences between murder and manslaughter in the state’s penal code but also shared, albeit “in general terms,” the differences in sentencing for both crimes, according to the appellate court panel’s opinion.
Another juror appeared to confirm the account, the justices noted.
The appellate court panel found that the judge should then have tried to learn exactly what the juror had said to his fellow jurors during deliberations, but that “no such inquiry was made.”
The justices noted that the jury that heard the case against Bright was sharply divided as to which type of homicide Bright had committed and sent several notes to the court stating that it was deadlocked before eventually reaching its verdict.
Without a more complete inquiry into what the juror shared with the rest of the panel, “we cannot say with confidence his discharge and the court’s general admonition to the jury not to consider sentencing were sufficient to cure the taint caused by the misconduct. Under the circumstances, without confidence in the impartiality of the jury, we have no choice but to reverse the judgment,” Presiding Justice Dennis M. Perluss wrote on behalf of the panel.
Bright was sentenced last year to 16 years to life in state prison.
The motive for the attack was unclear, but the two had been drinking and arguments between them had been escalating throughout the night, Deputy District Attorney Heather Steggell said after the verdict.
Bright — who claimed the stabbing was in self-defense — was arrested near the scene of the crime.
The two had known each other since middle school and attended Laguna Beach High School together, Gray’s mother told the OC Register shortly after her son’s death.