Facts: James Jaime was convicted of murder in the Superior Court for Yakima County following a trial that was held in a courtroom in the county jail rather than in the county courthouse due to alleged security concerns. Jaime subsequently appealed his conviction, asserting that holding the trial in the jail was unfairly prejudicial and inconsistent with his right to due process under the 14^th Amendment to the United States Constitution.

Question(s): Did the location of Jaime’s trial unduly erode the presumption of innocence?

Conclusion: Justice Stephens’ opinion for the Court concluded that although holding a trial in a jailhouse setting is not constitutionally impermissible under all circumstances and may be appropriate given sufficiently serious security concerns, these must be carefully balanced against the potentially significant prejudicial effect of such a change in venue. Applying this standard, the Court ruled that the trial court had abused its discretion in relocating the trial and unnecessarily eroded the presumption of innocence in a manner that violated Jaime’s right to due process insofar as it had not made any official findings of fact to support this decision and considered impermissible factors in reaching it. Thus, the Court vacated Jaime’s conviction and remanded the case.

Docket No. 82008-2 (from Yakima Case No. 05-1-03114-5)

Appellant: James Jaime

(Counsel: Stephanie C. Cunningham)

Respondent: State of Washington

(Counsel: Kevin Gregory Eilmes)

Briefs:

Argument: Thursday, May 14, 2009 9:00am

[Source: TVW, http://tvw.org]

Decided: Thursday, May 27th, 2010

Prevailing Party: James Jaime (Appellant)

Vote: 6-3

Citation: Pending

Court: Madsen1 Court (2010-)

Alexander
(Concurs)

Johnson

Madsen

Sanders
(Concurs)

Chambers

Owens

Fairhurst
(Dissent)

Johnson
(Dissent)

Stephens
(Majority)