On May 27, 2010, the Washington State Supreme Court, sitting en banc, held that a trial and subsequent conviction that took place in a jailhouse courtroom violated the defendant's right to due process by eroding the presumption of innocence.
Defendant James Frank Jaime was charged with second degree murder in the December 27, 2005 death of Ignacio Ornales, who was shot during an apparent drug deal. During pretrial proceedings the possibility of holding Jaime's trial in a courtroom located in the jail across the street from the courthouse was raised. Defense counsel strenuously objected contending this was akin to shackling Jaime in front of the jury. The prosecution argued that holding the trial in the jailhouse was necessary for security reasons and that it would actually benefit Jaime because he would otherwise need to be handcuffed for transport between the jail and the courtroom and there was a risk jurors would see him during transport.
After hearing both sides, the court decided to hold Jaime's trial in the jail. The jury convicted Jaime of second degree murder and he appealed. The Court of Appeals certified the case for direct review.
The Washington State Supreme Court held that holding a trial in a jail is inherently prejudicial. In referring to a somewhat analogous case where a trial was held in an Oregon prison, State v. Cavan, 337 Or. 433, 98 P.3d 381 (2004), the Washington court noted that "Both settings are places 'that the public, as a general matter, is unlikely to visit', where the jury's safety and 'to a large extent, the trial itself, are in the control of the [facility's] administrators and corrections personnel.' Most importantly, a jail, like a prison, 'forcefully conveys to a jury the overriding impression of a defendant's dangerousness and ... by extension, his or her guilt.'"
With regard to the supposed need for added security during Jaime's trial, the court noted that for potentially prejudicial measures to be implemented (the use of shackles in the courtroom, for instance) "The judge's decision must take into account 'specific facts relating to the individual' and be 'founded upon a factual basis set forth in the record.'" In the instant case the trial court conducted no fact-finding, instead relying only on the prosecutor's unverified representations. Thus, the Supreme Court held that holding Jaime's trial in the jail was not based on a factual record therefore it could not be said that the measure was "necessary to further an essential state interest." The court concluded that the setting of Jaime's trial "infringed upon his right to a fair and impartial trial." As such the decision of the trial court was reversed and the case remanded for a new trial. See: State v. Jaime, 168 Wash.2d 857, 233 P.3d 554 (Wa. 2010).
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Related legal case
State v. Jaime
|Cite||168 Wash.2d 857, 233 P.3d 554 (Wa. 2010).|
|Level||State Supreme Court|