Stevens v. Beard
- J. Davila
- 5:13-cv-03877
- U.S. District Court · Northern District of California
- 5
In Stevens v. Beard, Judge J. Davila held racial bias by a juror required vacating the judgment and ordered trial proceedings or release.
Joseph E. Stevens, whose murder judgment was vacated and whose case was sent back to the trial court; he was to be released from state custody unless the State initiated trial proceedings within 90 days.
What happened
In Stevens v. Beard, Joseph E. Stevens challenged his murder convictions after a juror reported making a racially biased statement during deliberations. The court had previously set aside the verdict and held an evidentiary hearing to determine whether the statement was prejudicial.
The court found that Juror No. 12 made the statement and that it showed deep racial bias. Because racial bias by a juror is a fundamental error that makes a fair trial impossible, the court found that it did not need separate proof of prejudice.
Judge J. Davila adopted Stevens’s proposed findings and conclusions, affirmed the earlier decision vacating the judgment, and sent the case back to the trial court. The court ordered Stevens released from state custody unless the State begins trial proceedings within 90 days.
The detailed version
- Stevens v. Beard · No. 5:13-cv-03877
- J. Davila
- Sept. 29, 2022
Background
A jury found Joseph E. Stevens guilty of two murders and found firearm and multiple-murder special-circumstance allegations true. The trial court sentenced him to two life terms without the possibility of parole, two consecutive firearm-enhancement terms of 25 years to life, and three years for an assault conviction. The California Court of Appeal affirmed the judgment, and the California Supreme Court denied review.
On August 22, 2018, this court granted Stevens’s petition for a writ of habeas corpus—a request for relief from unlawful custody—and ordered the verdict set aside. The court then granted the State’s request for an evidentiary hearing about whether a statement by Juror No. 12 was prejudicial. The court permitted discovery and investigation involving the jurors.
Evidentiary Hearing
The court held the evidentiary hearing on April 27, 2022. It reviewed the trial record, depositions and transcripts involving Jurors No. 5 and No. 12, stipulated expected testimony from an inspector for the San Francisco County District Attorney’s Office, and a Department of Motor Vehicles photograph of Juror No. 12.
The court found that Juror No. 5 credibly reported that, during deliberations about the language and culture surrounding the Potrero Hill housing projects, Juror No. 12 made a racial statement referring to Black people. Juror No. 5 had reported the statement to the trial court in 2007 and later described it as an aside during the discussion. No other juror recalled hearing the racial epithet or other improper remarks. Juror No. 12 denied making the statement and testified that she was not biased against Black people.
Court’s Analysis
The court explained that the Sixth Amendment guarantees a criminal defendant a verdict from impartial jurors. It treated racial bias by a juror as structural error—an error affecting the basic fairness and reliability of the trial. Because the court found that Juror No. 12 made the racially inappropriate statement and that the statement demonstrated deep bias, it concluded that prejudice had to be assumed and that the error required relief.
Disposition
Judge J. Davila adopted Stevens’s proposed findings and conclusions of law. The court affirmed its earlier decision to vacate the judgment against Stevens and remanded the case to the trial court. Unless the State initiates trial proceedings within 90 days, the court ordered that Stevens be released from state custody. The Clerk was directed to close the file.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.