Attorney General v Dallas

Attorney General v Dallas

The defendant, while serving as a juror, deliberately disobeyed unequivocal judicial directions not to conduct internet research or disclose extraneous information, thereby prejudicing the administration of justice and causing a mistrial. This conduct constitutes contempt of court proved to the criminal standard.

Parties
Claimant: Her Majesty's Attorney General; Defendant: Theodora Dallas
Jurisdiction
England and Wales
Judgment Date
23 January 2012
Procedural Posture
Contempt of Court Application / Judgment After Hearing of Committal Application
Outcome
Application for committal granted; defendant found in contempt of court.
Legal Topics
Juror Misconduct, Internet Research by Jurors, Committal for Contempt, Jury Directions, Fair Trial
Criminal Law Contempt of Court Jury Trials Juror Misconduct Internet Research by Jurors Committal for Contempt Jury Directions Fair Trial

Case Brief

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Parties

Her Majesty's Attorney General

Claimant

Theodora Dallas

Defendant

Procedural Posture

Contempt of Court Application / Judgment After Hearing of Committal Application

Legal Issues

  1. 1 Whether the defendant committed contempt of court by conducting internet research during jury service and disclosing it to fellow jurors
  2. 2 Whether the committal proceedings under Order 52 of the Rules of the Supreme Court were appropriate
  3. 3 Whether the defendant deliberately disobeyed a judicial direction

Ratio Decidendi

The defendant, while serving as a juror, deliberately disobeyed unequivocal judicial directions not to conduct internet research or disclose extraneous information, thereby prejudicing the administration of justice and causing a mistrial. This conduct constitutes contempt of court proved to the criminal standard.

Court Disposition

Application for committal granted; defendant found in contempt of court.

Orders

  • Defendant committed to six months' imprisonment, to serve three months.
  • No order for costs.