Impeachment of a Criminal Jury Verdict – West Virginia v. Greenfield

gavelA jury’s verdict in a criminal matter is entitled to great deference by the courts.  Even if a judge, or the parties, may disagree with the outcome that a jury reaches, if the verdict was reached through proper court procedures and was a reasonable result of the evidence presented, jury verdicts will rarely be overturned. Criminal defendants can attack the merits of a jury verdict in two ways. First, they may argue that the verdict was unfairly influenced by things that happened at trial, such as the presentation of evidence that should have been excluded, or a lack of evidence that would support the verdict reached.

Alternatively, defendants can attack the process of reaching the verdict itself, including arguing  that jurors were influenced in the jury room by outside information, or that they acted in such a manner during deliberations as to discredit the verdict. A recent case before the West Virginia Supreme Court of Appeals looks at a defendant’s efforts to invalidate a jury verdict by arguing it was improperly reached.

In West Virginia v. Greenfield, Mr. Greenfield was convicted of the first-degree murder of his wife. At trial, evidence was presented to show that Mr. Greenfield and his wife were separated at the time but continued to have ongoing disputes. Mr. Greenfield’s new girlfriend had reported to his father that she was worried that Mr. Greenfield might harm his ex-wife and that he had previously threatened to kill her. On the night of August 21, 2013, Mr. Greenfield went over to his wife’s home with his children to drop them off. Before he left, Mr. Greenfield’s girlfriend and his father both urged him to stay calm. Later that evening, Mr. Greenfield’s father received a call from Mr. Greenfield, in which he confessed to killing his wife by hitting her repeatedly with a hammer. He said he had gone crazy.  Evidence was also presented that Mr. Greenfield had spoken with his sister and told her that he had killed his wife by striking her with a hammer. After Mr. Greenfield returned home, his girlfriend testified that he also admitted to her that he had killed his wife.  When Mr. Greenfield’s father drove to his daughter-in-law’s home, he called 9-1-1, and emergency responders found Mr. Greenfield’s wife dead, with a hammer next to her body. Mr. Greenfield was also found covered in blood-stained clothing.

After the trial ended, the jury deliberated for only 70 minutes before finding Mr. Greenfield guilty. The lower court denied Mr. Greenfield’s post-trial motions for a judgment of acquittal or a new trial, and he was sentenced to life in prison.  On appeal, Mr. Greenfield argued that the verdict should be overturned because 70 minutes was not enough time for a jury to adequately consider the instructions of the court and the evidence presented at trial. Instead, Mr. Greenfield contended that the jury must have based its rulings on the emotional nature of the crime rather than actual evidence of his guilt. In response, the State of West Virginia noted that the trial itself took only two days, that the jurors heard extensive explanations of the evidence during those two days, and jurors could have easily reached the conclusion of guilt during deliberations.

In West Virginia, a verdict may be impeached or contested based on the jury’s actual deliberation only in limited circumstances. There are two different types of challenges to the conduct of jurors – intrinsic challenges based on the jury’s deliberation process and extrinsic challenges based on outside evidence or actions that may have contributed to the jury’s verdict. Generally, while jury verdicts may be affected by extrinsic matters, it is very hard to contest a jury’s intrinsic process because of the policy of protection that we attach to the privacy and integrity of the deliberation process.

In West Virginia, a challenge concerning how long it has taken a jury to deliberate is considered to be an intrinsic challenge that courts will rarely consider. This is because the length of deliberations is rarely seen as reflecting the seriousness that jurors gave to deliberations. Without knowing that an improper outside event took place, allegations that the jurors simply did not deliberate for long enough is no more than an assumption of juror misconduct without justification. Here, there was overwhelming evidence of guilt, and the West Virginia Supreme Court held there was nothing improper about the short deliberation time.

Challenging a jury’s verdict is a very difficult thing to do because our justice system grants special protections to the integrity of the jury process and rarely allows defendants to peek into their decision-making. If you believe that you have been harmed as a result of a faulty jury verdict, you should speak with a West Virginia lawyer to determine the likelihood of success in your case. The West Virginia criminal defense lawyers at the Wolfe Law Firm have been serving clients in both state and federal courts for more than 25 years and can work with you to meet your legal needs without causing unnecessary financial stress. Call us at 1-877-637-5756 or contact us online for a free consultation.

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A Plea Deal Gone Wrong in West Virginia – State v. Fields

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