Law in Popular Culture

9th Circuit Cites ‘12 Angry Men,’ Says Holdout Juror Should Not Have Been Dismissed


A federal appeals court based in San Francisco has cited the classic film 12 Angry Men to illustrate why a holdout juror in a murder trial should not have been dismissed for bias.

The May 23 opinion (PDF) by the 9th U.S. Circuit Court of Appeals overturned the murder conviction of Tara Sheneva Williams, accused of sitting in a car while two friends robbed a liquor store, the National Law Journal reports. One of the friends was accused of shooting and killing the clerk.

The jury foreman had complained after Juror No. 6 told other jurors they should be “very convinced” of guilt beyond a reasonable doubt, the story says. Juror No. 6 had expressed an intent to disregard the law and a concern about the severity of the charge, the foreman said in a note to the Los Angeles County judge overseeing the case.

After questioning jurors, the judge expressed concerns that Juror No. 6 was applying a higher standard of proof than the law requires, and dismissed him because he was a “biased juror” whose “mind is bent” against the prosecution.

The unanimous panel opinion by Judge Stephen Reinhardt contrasted Juror No. 6’s statement with that of the Henry Fonda character in 12 Angry Men: “We’re talking about somebody’s life here. We can’t decide in five minutes. Supposin’ we’re wrong.”

In 12 Angry Men, the holdout juror persuades the others to acquit. Reinhardt contrasted the fictional movie with the trial of Williams, who was convicted after the holdout was removed. The Sixth Amendment “does not allow a trial judge to discharge a juror on account of his views of the merits of the case,” he wrote.

A panel of lawyer film experts ranked 12 Angry Men as one of the 25 greatest legal movies in a 2008 ABA Journal story.

Updated at 11 a.m. to correctly identify the date of the opinion.

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