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Chambers v. State

The State failed to carry its burden of proving beyond a reasonable doubt that juror misconduct involving the introduction of extra-judicial information did not prejudice the defendant.

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In connection with the shooting death of 17-year-old Wendell “L. J.” Lewis Gilliam, Jr., Philmon Chambers, who also was 17 years of age at the time of the shooting, was charged with aggravated assault by use of a deadly weapon, felony murder, and murder. A jury found him guilty of aggravated assault, felony murder, and voluntary manslaughter as a lesser included offense of murder. After the trial court merged the three counts, Chambers was sentenced for committing voluntary manslaughter. His motion for new trial was denied.

In this appeal, Chambers contends that the trial court erred by, among other things, denying his motion for new trial, which motion raised the issue of juror misconduct. Specifically, Chambers complained that, during deliberations, a juror shared with her fellow jurors legal definitions, which she had found by using the Internet search engine Google; at least one such definition, Chambers argued, was incompatible with an affirmative defense he pursued at trial—defense of habitation, as it pertains to motor vehicles. Because Chambers has demonstrated on appeal that the state failed to carry its burden of proving beyond a reasonable doubt that he was not prejudiced by the juror misconduct, we reverse the trial court’s denial of his motion for new trial. Chambers’s remaining claims of error, for purposes of this appeal, are moot.

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