What is the test for a motion to compel the release of juror identification information?

California, United States of America


The following excerpt is from People v. Mayer, B230332 (Cal. App. 2012):

To demonstrate good cause for the release of juror identification information pursuant to Code of Civil Procedure section 237, subdivision (b), a defendant must "set[ ] forth a sufficient showing to support a reasonable belief that jury misconduct occurred." (People v. Rhodes (1989) 212 Cal.App.3d 541, 552; accord People v. Jefflo (1998) 63 Cal.App.4th 1314, 1321, fn. 8.) Further, the misconduct alleged must be "'of such a character as is likely to have influenced the verdict improperly.'" (People v. Jefflo,

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supra, at p. 1322.) A petition to disclose juror identification information must be supported by more than mere speculation and may not be used as a "'fishing expedition[]' by parties hoping to uncover information to invalidate the jury's verdict." (People v. Rhodes, supra, 212 Cal.App.3d at p. 552.)

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