Supreme Court Says Juror Misconduct Did Not Influence Guilty Verdict in Murder Case

May 16, 2013

The Tennessee Supreme Court has affirmed the conviction of a man serving a life sentence for the 2006 first degree premeditated murder of his girlfriend.

On April 16, 2006, Prince Adams was at his mother’s residence in Shelby County and then left with Ohrdra Flowers in her automobile. Two days later, Adams informed his cousin that he had fought with Flowers and had killed her with his pocketknife after she admitted to an affair with another man. Adams later confessed to the police.

After the jury returned a guilty verdict on the charge of first degree murder, the jury foreman notified the trial judge that he had discovered a note in his hotel room the previous night, indicating that the two alternate jurors thought Adams was guilty as charged. The alternate jurors had been released from service before deliberations began. Claiming misconduct on the part of the alternate jurors, Adams sought a new trial. The trial court denied the request after the foreman testified that the note did not affect his or any other juror’s view of the evidence. The Court of Criminal Appeals upheld the conviction.

The Supreme Court granted the appeal to clarify that the note qualified as an “improper outside communication,” which as a matter of law results in a presumption that the jury was prejudiced and the guilty verdict should be set aside. In a unanimous opinion, the Court held that even though the note was improper, the prosecution had successfully overcome the presumption of prejudice by introducing other evidence to demonstrate that the communication had no effect on the jury’s deliberations.

The Court further observed that under the rules the foreman should not have been allowed to testify about the effect the note had on his view of the evidence, but in this instance there was no reasonable possibility that the verdict was influenced by the note. In reaching this conclusion, the Court considered the nature and content of the communication, the number of jurors who were aware of the note, the manner and timing in which the foreman received the note, and the weight of the remaining evidence at trial.

The Court also rejected Adams’ claims of other errors in the trial. He is serving a life sentence for the murder.

To read the State of Tennessee v. Prince Adams Opinion, authored by Chief Justice Gary R. Wade, visit the Opinions section of TNCourts.gov .