Anonymous jury does not violate public trial right

CALIFORNIA–A state appellate panel in Los Angeles unanimously held in early December that a criminal defendant’s Sixth Amendment rights to a fair and public trial were not violated when he was tried by jurors whose names were kept secret and who were referred to only by assigned juror identification numbers.

The court held that although the jurors’ names were not stated aloud in court and thus not transcribed into the record, the jury was not anonymous because the court and counsel had available to them a list with the prospective jurors’ names and corresponding identification numbers.

In a footnote, the court said that there was no evidence in the record that “interested members of the public or the news media were precluded from ascertaining jurors’ names during the trial.”

The defendant, Byron Goodwin, was tried by a Los Angeles County Superior Court jury for burglary after he attempted to get a refund for a pair of pants that he had shoplifted from a Sears store. Pursuant to a court rule implemented in September 1996, judges presiding over criminal trials have discretion to seal personal juror identifying information such as names, addresses and telephone numbers. The rule makes it a misdemeanor to improperly obtain or release sealed juror information.

The jury convicted Goodwin, and he was sentenced to a prison term of 25 years to life under the “Three Strikes Law.” Goodwin appealed the conviction, arguing he was denied his right to a public trial as guaranteed under the Sixth Amendment. Goodwin also argued that because the jury probably assumed that the need for secrecy was related to his dangerousness, it created a presumption of guilt.

Although the appellate court upheld Goodwin’s conviction, it questioned the “wisdom and practicality” of the court rule, noting that the parties to the action “all decried the impersonality and dehumanization of a process which refers to people only by number and not by name.” (California v. Goodwin; Defendant’s Attorney: Thomas Coleman, Los Angeles)