Published on Texas District & County Attorneys Association (http://www.tdcaa.com)
Uranga v. State - 6th COA

A mistrial should not have been granted once a juror realized, after seeing the defendant drive across the juror's yard in a video of the defendant's car-chase, that the defendant was the previously unknown person who had driven through the juror's yard, thereby making him a victim of the defendant's extraneous conduct. There is no implied bias when it is discovered in the middle of a punishment trial that a juror is a victim of the defendant's extraneous (misdemeanor-level) conduct that requires granting a mistrial. Also, the denial of a mistrial was not an abuse of discretion because the trial court concluded the juror would remain unbiased based on his repeated assertions. Uranga v. State, 06-07-00017-CR [1].

Source URL: http://www.tdcaa.com/node/2172

Links:
[1] http://www.6thcoa.courts.state.tx.us/opinions/htmlopinion.asp?OpinionId=9150