A jury trial that takes place in a prison courtroom does not necessarily violate a defendant's right to a fair trial, the Utah Supreme Court ruled Friday.
The high court ruled Eric Thomas Daniels' 1997 capital murder trial held within the walls of the Central Utah Correctional Facility in Gunnison was constitutional, given the security concerns surrounding the case.
Daniels was convicted of the July 6, 1994, jailhouse murder of Lonnie Blackmon. He was serving a sentence for forgery at the time. Daniels held the legs of Blackmon, 32, while another inmate, Troy Michael Kell, stabbed Blackmon 67 times with a metal shank.
Prosecutors sought the death penalty against Daniels, but jurors voted 10-2 to sentence him to life in prison without the possibility of parole.
Kell was convicted of capital murder and sentenced to death for the racially motivated slaying. His appeal is pending before the Utah Supreme Court.
On appeal, defense attorneys argued Daniels was denied his right to a fair trial; the judge failed to instruct jurors they could find Daniels guilty of a lesser charge of manslaughter; and the state constitution guarantees a unanimous jury at sentencing.
The trial inside the prison was "inherently prejudicial" because jurors may have believed Daniels was dangerous and needed to separated from the community, his attorneys said.
The justices disagreed in Friday's unanimous opinion, saying jurors could have inferred a number of things from the setting.
For instance, they could have thought it easier than transporting the numerous incarcerated witnesses to the courthouse; it enabled prison officials to testify without traveling; it allowed jurors to tour the crime scene; or that the prison courtroom was more modern and better equipped.
"It is equally likely that jurors may have inferred that the trial took place in a prison courtroom because of the circumstances surrounding the nature of the case and that the location of the trial had nothing to do with the defendant's character," the opinion states.
The justices also determined that while the constitution mandates a unanimous jury when determining guilt or innocence, one is not required in determining a sentence for someone who has already been convicted.