Dec. 7, 2022 – People v. Carabajal (1st Dist., Div. 3, A162212)

Several months after defendant’s trial, the prosecutor informed defendant that on the second-to-last day of trial one of the sitting jurors had applied for a job as a victim-witness advocate with the prosecutor’s office and had subsequently been hired. After holding a hearing at which the juror testified, the trial court found no actual bias and denied defendant’s motion for new trial. The Court of Appeal affirms, holding that there is substantial evidence to support the finding of no actual bias, and that “the instant matter does not present an extraordinary case in which bias should be implied as a matter of law.”