New York Court of Appeals
The People of the State of New York v. Fred De Lucia and Salvator Montella
July 7, 196720 N.Y.2d 275
Summary
The Court reexamined New York's common-law rule barring jurors from impeaching their own verdicts and held that, when jurors engage in an unauthorized visit to the crime scene, such outside influence violates the Sixth Amendment right to confrontation and warrants a new trial if the allegations are substantiated. Accordingly, the convictions were vacated and the case was remanded for a hearing on the jurors' conduct. A dissent argued that the majority incorrectly overruled prior precedent and that the convictions should stand.