A state appeals court panel this month reversed a Laguna Beach man’s conviction for the fatal stabbing of a longtime friend at a Santa Monica apartment in 2012.
Los Angeles Superior Court Judge James Dabney should have conducted a more detailed inquiry into what a juror told his fellow panelists during deliberations about his outside research into the difference between murder and manslaughter before he was excused from the jury, according to the 12-page ruling by the three-justice panel from California’s 2nd District Court of Appeal.
The panel thus ordered the case against 30-year-old Ryan Taylor Bright be sent back to Superior Court for retrial.
Bright and his close friend and Laguna Beach High School classmate Jensen Gray were partying in an apartment near Santa Monica's Third Street Promenade on July 11, 2012, when 27-year-old Gray was stabbed to death.
Bright, who was arrested near the scene of Santa Monica's first murder that year, claimed he acted in self defense after he and Gray had been drinking and arguing.
During the trial, Judge Dabney dismissed one juror after it was revealed he independently contacted a prosecution witness, looked up the difference between murder and manslaughter in the state penal code and shared with jurors what the sentencing differences are for those crimes.
Dabney empaneled a new member of the jury, which in December 2014 found Bright guilty of second-degree murder. He was sentenced last year to 16 years to life in state prison.
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The appellate court panel agreed with Bright's lawyers that Dabney failed to conduct a thorough enough investigation to determine whether the rogue juror tainted the whole jury, which would have prompted the judge to declare a mistrial.
Noting that the jury was sharply divided as to which type of homicide Bright had committed and sent several notes to the court stating that it was deadlocked before eventually reaching its verdict, Presiding Justice Dennis M. Perluss wrote on behalf of the appellate panel, “we cannot say with confidence his discharge and the court’s general admonition to the jury not to consider sentencing were sufficient to cure the taint caused by the misconduct. Under the circumstances, without confidence in the impartiality of the jury, we have no choice but to reverse the judgment."