People v. Wiggins: Trial‑Court Discretion and Allegations of Racial Bias in Jury Deliberations

I. Introduction

In People v. Wiggins, 2025 NY Slip Op 06539 (Nov. 25, 2025), the New York Court of Appeals confronted one of the most sensitive and difficult questions in criminal procedure: what must a trial judge do when a sitting juror alleges that other jurors have expressed racial bias during deliberations, and when, if ever, does such an allegation compel a mistrial?

The majority opinion by Judge Garcia affirms the defendant’s convictions and holds that, on this record, the trial court did not abuse its discretion in denying a mistrial. The Court reinforces two propositions:

The governing standard for removing a sworn juror is the “grossly unqualified” test under CPL 270.35 as developed in People v. Buford, Spencer, and Kuzdzal; and
Appellate review is highly deferential: unless the record convincingly demonstrates that a juror cannot render an impartial verdict, denial of a mistrial will stand.

Judge Rivera’s lengthy dissent, by contrast, would have ordered a new trial based on uncontroverted allegations that at least half the jurors engaged in racially charged commentary, as reported by the only juror of color. The dissent explicitly frames the case in the context of implicit bias, the Supreme Court’s decision in Peña‑Rodriguez v. Colorado, and the New York court system’s recent initiatives to combat racial prejudice in jury service.

The decision is significant because it clarifies how New York courts are to respond to allegations of racial bias in the jury room, delineates the limits of judicial inquiry into deliberations, and underscores the central role of trial‑court discretion and preservation doctrine in this area.

II. Factual and Procedural Background

A. The Underlying Criminal Case

Defendant Jaylin Wiggins was tried in Erie County on charges arising from two separate shootings in Buffalo in the early morning hours of August 4, 2016:

At approximately 1 a.m. on Maple Street, one victim was shot and wounded.
About an hour later, on Sherman Street, a second shooting left one victim dead and two injured.

The prosecution’s theory linked the same shooter to both incidents, relying heavily on distinctive clothing: a cream or beige “Burberry‑type” plaid shirt and white pants. Surveillance video from the Sherman Street scene showed three shooters, but their faces were indistinct. One shooter—closest to the dead victim—wore the white pants and light plaid shirt. A separate surveillance video from Buffalo City Court, taken about 12 hours earlier, showed the defendant wearing clothing matching that distinctive description. Forensic and medical testimony linked the fatal shot to the person in that clothing in the Sherman Street video.

The jury convicted Wiggins of:

Second‑degree murder,
First‑degree assault, and
Second‑degree criminal possession of a weapon,

and acquitted him of two counts of attempted murder (one of which had been dismissed by the People at the close of their case).

B. The Jury and the Allegation of Racial Bias

The crucial events occurred during deliberations. Juror 5—the sole juror of color on an otherwise all‑white 12‑person jury; the defendant is Black—sent an unsanctioned handwritten note directly to the judge, not signed by the foreperson as instructed. Among other things, it stated:

“I was told on Friday that all black people look the same in the dark. That’s insulting to me, I do not want to be [bullied] into rushing my decision.”

The same note requested to re‑view the Sherman Street video and to rehear the closing arguments and also mentioned perceived conduct in the courtroom (a person in the audience “squirming” to catch her attention, smiles from the assistant district attorney, an officer patting another officer).

After the court re‑instructed the jury on proper note procedures, a second note—this time signed by the foreperson and initialed by Juror 5—requested evidence but omitted any mention of racial remarks. When the second note was discussed, defense counsel explicitly referenced the racial comment from the first note and asked the court to “note our exception” to possible evidence of racial bias.

C. The Trial Court’s Inquiry (the “Buford”‑type Hearing)

The court, insisting that the racial‑bias issue be addressed, proposed to question Juror 5 and the juror who allegedly made the comment (ultimately identified as Juror 10). Both parties agreed on that course, with the shared constraint that the court should not delve into the substance of the jury’s deliberations.

1. Juror 5’s Testimony

Key points from Juror 5’s in‑camera examination:

She confirmed that on Friday, during deliberations, a juror stated that “all Black people look the same at night” (or words very close to that effect) and identified Juror 10 as the speaker.
She stated she could still be fair and impartial despite finding the remark insulting.
In response to defense counsel, she reported that approximately six white jurors had expressed “bigotry”:
- They made statements suggesting that Black people live a “whole different culture” and life from white people and tying Black people generally to gang and crime‑related behavior.
- She confronted them, expressed that she “didn’t appreciate” those statements, and, according to her, they reflected and apologized the next day.
Crucially, when asked if she could assure that the racial animus had been extinguished, she responded: “I don’t know if it’s been extinguished. I cannot guarantee it.”

Following this testimony, defense counsel immediately moved for a mistrial, arguing that at least half the jurors were “impermissibly tainted with racial bias” and that the available alternates were numerically insufficient to cure the problem by substitution. Counsel opposed questioning additional jurors, insisting that only a mistrial could “fix” the situation.

2. Juror 10’s Testimony

The court nonetheless called in Juror 10. She did not flatly deny making the statement but attempted to recast it:

She said she “didn’t make it in that way” and referenced her Asian daughter, stating she would not want someone to accuse her daughter based solely on looks in a low‑visibility video.
Asked whether other jurors expressed the same sentiment—that “all Black people look the same in the dark”—she responded that things had been “rushed on Friday,” but “No. Not in that manner.”
She stated she could continue as a fair and impartial juror.
She explained that the discussion emerged from disagreement about whether re‑viewing the surveillance video would aid identification in grainy nighttime conditions; she said the focus had been on clothing, not faces, and denied any discussion “that would smack of racial prejudice.”

Defense counsel renewed the mistrial motion. Notably, throughout this process counsel:

Did not ask that Juror 5 be removed as “grossly unqualified,” despite having previously complained she had “nodded off” during the charge and then expressly consenting to her continued service; and
Did not request substitution of Juror 10 with an alternate.

The trial court denied the mistrial, allowed deliberations to continue, and the jury ultimately returned the guilty verdicts.

D. Post‑Verdict Motion and Appellate History

After trial, the defense moved under CPL 330.30 to set aside the verdict, again asserting juror racial bias. The trial court denied the motion, emphasizing:

Juror 10’s denial of the specific racist wording and her alternative explanation;
The possibility that Juror 5 misinterpreted what was actually said; and
That the defense never requested removal of either juror in favor of alternates.

The Appellate Division, Fourth Department, affirmed (225 AD3d 1305 [4th Dept 2024]), holding that the trial court:

Conducted an “appropriate inquiry into this most serious charge” of racial bias; and
Properly balanced the defendant’s right to an impartial verdict with the jury’s right to deliberate free from undue interference.

Two Justices dissented, unable to conclude that the jury was untainted by racial bias. A dissenting Justice granted leave to appeal to the Court of Appeals. The high court now affirms.

III. Summary of the Court of Appeals’ Decision

A. Majority Holding

The Court of Appeals (Garcia, J.) holds:

The trial court did not abuse its discretion in denying the mistrial motion following its inquiry into the alleged racial comments during deliberations.
The record supports the trial judge’s conclusion that:
- Juror 10’s statements arose in the context of a legitimate evidentiary debate about the reliability of nighttime, grainy video as identification evidence, and
- What Juror 5 perceived as racial bias may have reflected a misunderstanding of that context or subsequent clarification and reflection by other jurors.
Mere reference to race during deliberations, especially when discussing identification in low‑light video, does not itself establish racial bias infecting the verdict.
Because defense counsel expressly opposed the questioning of other jurors and requested only a mistrial, the only issue preserved for appellate review is the denial of that mistrial; possible alternative remedies (further inquiry, substitution of jurors) are not before the Court.

The Court also rejects the defendant’s additional contentions:

The challenge regarding failure to read the complete jury note into the record is unpreserved (see People v. Mack).
The claim that Juror 5 was “grossly unqualified” because she slept through jury instructions is likewise unpreserved.
The Appellate Division’s weight‑of‑the‑evidence review applied the correct legal standard, rendering that determination beyond the Court of Appeals’ power to review (see People v. Kancharla).

Accordingly, the order of the Appellate Division is affirmed.

B. The Dissent

Judge Rivera dissents. She views the record as revealing uncontroverted allegations that deliberations were “tainted with racial tropes,” made by at least six jurors, and that nothing the court could do at that stage could cure the damage. In her view:

Once the sole juror of color reports that multiple jurors have made racist and stereotypical remarks about Black people—and cannot assure that racial animus has dissipated—a mistrial is the only way to guarantee a fair trial.
Questioning other jurors risks defensiveness and may worsen racial tensions; further voir dire would neither reliably uncover implicit bias nor dispel its effects.
The majority underestimates both the impact of such comments on deliberations and the complex, often unconscious nature of racial bias.

She would reverse and order a new trial on the counts of conviction.

IV. Analysis

A. Precedents Cited and Their Role in the Decision

1. CPL 270.35, Buford, and the “Grossly Unqualified” Juror

CPL 270.35(1) provides that if, after the jury is sworn and before verdict, the court finds that a juror is “grossly unqualified” to serve, the court must discharge that juror; if there is no alternate, a mistrial must be declared (People v. Spencer, 29 NY3d 302, 309 [2017]).

In People v. Buford, 69 NY2d 290 (1987), the Court of Appeals established the standard procedure when a concern arises that a sworn juror may be unqualified:

The trial court must conduct a “probing and tactful inquiry” of the juror,
Evaluate the nature and significance of what the juror has seen, heard, or experienced, and
Assess whether that juror’s state of mind “would prevent the rendering of an impartial verdict.”

A juror is “grossly unqualified” only when the record “convincingly demonstrates” that the juror cannot render an impartial verdict (Spencer, 29 NY3d at 310).

Wiggins expressly reaffirms this framework and emphasizes that trial courts have “broad flexibility” when investigating allegations of juror misconduct or bias, particularly because they can observe the jurors’ demeanor and the dynamics of the trial first‑hand (People v. Kuzdzal, 31 NY3d 478, 485–486 [2018]).

2. Kuzdzal and the Court’s “Broad Flexibility”

In Kuzdzal, the court underscored that when presented with “credible information” that a sworn juror may be grossly unqualified, a trial court must conduct a “probing and tactful” inquiry. However, it also recognized:

The sensitive nature of probing potential juror misconduct or bias; and
The necessity of avoiding undue intrusion into jury deliberations themselves.

Wiggins leans heavily on this theme. Judge Garcia repeatedly highlights the “delicate and complex” nature of such investigations and uses Kuzdzal to justify deference to the trial judge’s choice of remedy and the limited scope of questioning. The majority sees its role as confined to deciding whether the trial court’s resolution of conflicting juror accounts—particularly its credibility assessment of Jurors 5 and 10—was outside the range of reasonable discretion. It concludes it was not.

3. Limits on Probing Deliberations: Sanchez

In People v. Sanchez, 99 NY2d 622 (2003), the Court warned that it would be “unnecessary and indeed inappropriate” to subject jurors to questioning about their thought processes, the substance of deliberations, or other matters within the “confines of the jury room.” Wiggins explicitly invokes this principle to:

Justify the limited scope of the inquiry into what was said,
Reject the notion that the court was required to quiz every juror individually, and
Support the view that further probing—especially into the details of racial discussions—risked impermissible encroachment on deliberative secrecy.

4. Explicit Racial Bias Cases: Rodriguez and Fisher

The majority confronts, and distinguishes, a line of cases in which a juror’s own statements unequivocally establish racial or ethnic prejudice:

People v. Rodriguez, 71 NY2d 214 (1988): a juror “stated unequivocally that she was racially biased” toward the defendant.
People v. Fisher, 41 NY3d 495 (2024): the Court described circumstances where a juror “clearly holds” a racial bias “directly against the defendant” and is therefore presumed grossly unqualified.

In a footnote, Wiggins stresses that this is not such a case:

Juror 10 did not admit stating that “all Black people look the same in the dark” but claimed her remarks were about the inability to see anyone’s face in the grainy video, invoking her own (Asian) daughter to explain concern about misidentification.
The trial court thus faced a credibility dispute: whether to credit Juror 5’s interpretation as an expression of racial bias, or Juror 10’s explanation that she was cautioning against misidentification.

Because there was no unequivocal, self‑acknowledged racial animus “directly against” the defendant, the majority applies the more demanding Buford/Spencer standard rather than presuming gross unqualification.

5. Earlier Recognition of Racial Bias: Leonti

The Court acknowledges its longstanding recognition that juror racial or ethnic prejudice can vitiate a verdict. In People v. Leonti, 262 NY 256 (1933), uncontroverted post‑verdict evidence showed a juror had stated he “would never believe a Sicilian under oath.” The Court reversed, holding that the juror “never was eligible” and was disqualified “from the beginning.”

Wiggins does not repudiate Leonti, but distinguishes it as a case of uncontested bias. Here, by contrast:

The alleged racist statement was disputed; and
The trial judge found, based on demeanor and context, that Juror 10’s comments related to the reliability of the video rather than racial animus.

6. Preservation and Remedies: Bailey and Mack

Two preservation doctrines limit the Court’s review:

Remedy preservation – People v. Bailey, 32 NY3d 70 (2018):
- When counsel requests only a particular remedy, the appellate court generally reviews only the denial of that remedy, not unrequested alternatives.
- Here, defense counsel repeatedly insisted that a mistrial was the “only” acceptable remedy and argued against further juror questioning or substitution. Thus, “the only asserted error preserved for appellate review was the denial of the motion for a mistrial.”
Jury‑note claims – People v. Mack, 27 NY3d 534 (2016):
- The Court holds that the defendant’s complaint about the trial court’s handling (or incomplete reading) of the jury note is unpreserved because no timely objection was made.

These doctrines significantly narrow the issues the Court is willing to address and reinforce the message that counsel’s strategic choices at trial can sharply constrain appellate relief.

7. Weight of the Evidence: Kancharla

Citing People v. Kancharla, 23 NY3d 294 (2014), the Court reiterates that it lacks authority to reweigh the evidence where the Appellate Division has already conducted a proper “weight of the evidence” review. Thus, any suggestion that racial bias might be inferred from the closeness of the proof is legally irrelevant at the Court of Appeals level.

B. The Majority’s Legal Reasoning

1. The Central Question: Abuse of Discretion in Denying a Mistrial

The majority carefully notes that the defense did not challenge the procedure used by the trial court (i.e., the form of the inquiry), but only the refusal to grant a mistrial after that inquiry. Thus, the question before the Court is narrow:

Did the trial judge abuse his discretion in deciding, based on the jurors’ answers and his observation of their demeanor, that a mistrial was not required?

Because the standard is abuse of discretion, the focus is on the reasonableness of the trial judge’s evaluation of credibility and the adequacy of his chosen remedy, not whether appellate judges might have handled the situation differently in the first instance.

2. Contextualizing Juror 5’s Allegations

A key move in the majority’s reasoning is to place Juror 5’s allegations within the broader context of:

Earlier concerns that she had been “sleeping” during the court’s charge (which she denied);
Defense counsel’s eventual “consent” that she continue to serve; and
Her violation of instructions by sending an individual, unsanctioned note to the court, mixing multiple concerns (video evidence, perceived courtroom conduct, medication, and racial insult).

The majority does not disparage Juror 5’s account, but clearly suggests that the trial judge—who had observed this juror throughout the trial—reasonably could:

See her as earnest but perhaps prone to misapprehending procedure and possibly misinterpreting certain comments, and
View her allegations against Juror 10 as requiring careful testing rather than automatic crediting.

3. The Nature of the Racial Comment and Its Context

The most legally consequential sentence in the opinion is likely:

“The mere fact that race entered the jury’s deliberations does not establish that racial bias infected their verdict.”

The majority stresses that, in cases involving visual identification—especially from grainy nighttime video—jurors may legitimately discuss physical characteristics, including race, without harboring or expressing racial animus. Here, the Court emphasizes that:

The discussion arose specifically about whether the video allowed identification of faces or only clothing.
Juror 10’s explanation—focusing on limitations of the video, referencing her Asian daughter, and warning against misidentification—was not inherently incredible.
The trial judge, who saw and heard Juror 10, was best positioned to decide whether her remarks reflected racism or a flawed but race‑conscious attempt to grapple with evidentiary reliability.

Thus, while the Court does not minimize the seriousness of racial bias, it resists a rule under which any reference to race in deliberations automatically triggers a mistrial.

4. Handling the Additional Allegations About Other Jurors

Juror 5 also reported that approximately six jurors had made stereotypical remarks about Black people and gang/crime culture, and that she confronted them and obtained apologies. The majority gives this aspect less central weight for two reasons:

Defense counsel declined to have those other jurors questioned and argued against further individual voir dire—insisting instead that such questioning would be “impossible” and demanding a mistrial.
The trial court therefore never had the opportunity to test or confirm those allegations, and appellate review is limited to the discrete record actually created below.

In effect, the Court treats the defense’s strategy as both:

A waiver of alternative remedial paths (substitution, more targeted inquiry), and
A constraint on what can be argued on appeal: the only preserved grievance is the denial of a mistrial.

The majority also notes that the judge, in his post‑trial decision, concluded that some of what Juror 5 reported may have been misinterpreted and that the jurors’ subsequent apologies and amplified focus on the evidence suggested a self‑corrective process rather than entrenched animus.

5. Deference to the Trial Court’s Observations and Discretion

A recurring theme is that the trial judge:

Observed the jurors throughout the entire trial,
Was present for the in‑camera inquiries, and
Was uniquely situated to assess demeanor, tone, and sincerity.

The Court emphasizes that its role is not to “substitute our judgment as to the appropriate remedy for that of the trial judge.” Instead, it is to determine whether that remedy—here, denying a mistrial after a limited but targeted inquiry—fell within the broad range of acceptable choices. It finds that it did.

The majority also implicitly rejects the dissent’s framing that fairness here required a mistrial, noting that the law does not make any one juror (including Juror 5) “guarantee” a fair trial. That obligation falls to the court, which must weigh all the evidence before it—including conflicting juror testimony—and craft a tailored response.

C. The Dissent’s Competing Vision

Judge Rivera’s dissent should be understood as articulating a different calibration of the balance between:

Protecting the secrecy of deliberations and respecting trial‑court discretion, and
Ensuring robust protection against both explicit and implicit racial bias in the jury room.

1. Emphasis on Uncontroverted Racial Tropes and the Position of Juror 5

The dissent treats Juror 5’s account as essentially uncontroverted regarding the existence of racist comments:

Juror 5 credibly alleged that at least six jurors—including Juror 10—made statements tying Black people to criminal and gang culture and invoking the trope that Black people “all look the same at night.”
As the only person of color on the jury, she both personally felt insulted and was thrust into the role of confronting and educating her fellow jurors about their remarks during deliberations.
Crucially, she acknowledged that she could not guarantee that the racial animus had been extinguished.

To the dissent, these features demonstrate that race had gone from an evidentiary topic to a prejudicial frame that risked defining how jurors perceived the defendant and the evidence.

2. Skepticism about the Efficacy and Safety of Further Inquiry

While Buford and Kuzdzal demand a probing inquiry, the dissent stresses that once jurors are accused of racist statements, questioning them can:

Trigger defensiveness and social‑desirability bias (jurors may deny or rationalize their own bias);
Exacerbate racial tension within the jury; and
Be ineffective at uncovering implicit bias, which individuals may be unaware of or unwilling to acknowledge.

The dissent draws on social science research and on the Supreme Court’s reasoning in Peña‑Rodriguez to argue that racial bias—especially implicit bias—is both pervasive and difficult to detect through direct questioning. Thus, the absence of a clear admission from Juror 10 should not be dispositive. The fact that Juror 5, the only Black juror, perceived and was harmed by the comments, and that half the jury was implicated, tipped the balance for the dissent toward requiring a mistrial.

3. No Adequate Remedy Short of a Mistrial

The dissent also rejects the majority’s implicit suggestion that alternative remedies might have sufficed. Judge Rivera reasons that:

There were not enough alternates left to replace all potentially tainted jurors.
Even isolating and removing the worst offenders would not neutralize residual bias in the room or the effect that prior racist remarks could have had on others.
Given Juror 5’s inability to assure that racial animus was gone, continuing deliberations risked a verdict infected by prejudice.

Consequently, she concludes that the trial court abused its discretion by refusing the only remedy capable of ensuring a fair trial: a mistrial and new trial.

D. Impact on Future Cases and the Law of Juror Bias

1. Clarifying the Standard When Race Enters Deliberations

Wiggins does not create a wholly new doctrinal test, but it significantly clarifies how New York courts should treat allegations of racial bias during deliberations:

Race‑related discussion ≠ per se racial bias. Jurors may discuss race as an evidentiary factor (particularly in identification) without automatically rendering the jury tainted.
Explicit, unequivocal bias still triggers strong presumptions. When a juror admits a racist view directly about the defendant or the defendant’s group (Rodriguez, Fisher), gross unqualification is presumed. Wiggins does not weaken that.
Ambiguous or contested statements fall under Buford’s case‑by‑case approach. The trial court must conduct a tactful inquiry and then make a contextual judgment; the appellate court will rarely disturb that judgment absent clear error.

2. Reinforcing Deference and the Importance of Preservation

Practitioners should take away two procedural messages:

Deference is real. Appellate courts will defer heavily to trial judges on:
- What questions to ask,
- How far to probe, and
- Whether the record “convincingly” shows a juror’s inability to be impartial.
Remedy requests matter. When counsel insists that only a mistrial is acceptable and opposes alternative remedial measures (such as questioning additional jurors or substituting alternates), counsel may:
- Limit the court’s practical ability to explore or cure the problem, and
- Narrow the scope of appellate review to a single binary issue: mistrial or not.

Future defense counsel facing similar circumstances may consider:

Simultaneously requesting mistrial and, in the alternative, removal of particular jurors and substitution of alternates;
Asking for a tailored, record‑building inquiry of other jurors, while noting concerns about intruding into deliberations; and
Crafting objections that preserve jury‑note and juror‑qualification issues in real time.

3. Interaction with Implicit Bias and Equal‑Justice Reforms

The dissent situates Wiggins in the broader context of the New York court system’s post‑2020 initiatives on implicit bias, including:

Statewide juror orientation materials on implicit bias, and
Mandated jury instructions cautioning jurors to guard against prejudice.

The majority opinion, however, is notably restrained on implicit bias. It adheres to traditional Buford‑style analysis and emphasizes observable, admitted bias over structural or unconscious bias. As a result, Wiggins signals that, at least for now, New York will address implicit bias concerns primarily:

Prospectively (through education and jury instructions), and
Within the existing framework of gross‑unqualification and abuse‑of‑discretion review at the trial level.

The opinion leaves open further development of doctrines explicitly tailored to implicit bias (such as expanded voir dire or specific protocols when the sole juror of color reports bias), but it does not create them.

4. Tension Between Finality and Fairness in Racial‑Bias Claims

Finally, Wiggins highlights a growing tension in jury‑bias jurisprudence:

On one hand, racial bias is recognized as particularly corrosive to the legitimacy of verdicts and to public confidence in the justice system (Peña‑Rodriguez, Rukaj, Leonti).
On the other hand, the secrecy of deliberations, the difficulty of detecting implicit bias, and the high premium on finality and judicial economy invite narrow, deferential standards for appellate intervention.

Wiggins comes down on the side of deference and finality in a contested, intra‑jury racial‑bias allegation. The dissent makes clear that at least some members of the Court would elevate the systemic risk of racial prejudice above those considerations, particularly where the allegation comes from the only juror of color.

V. Simplifying Key Legal Concepts

Mistrial: Ending a trial without a verdict because something has occurred that makes it impossible to ensure a fair proceeding (e.g., juror misconduct, prejudicial error). The case can be retried.
Grossly Unqualified Juror (CPL 270.35): A sworn juror who, because of newly discovered facts, clearly cannot be fair and impartial—for example, a juror who admits racial prejudice against the defendant’s group. The court must remove such a juror; if no alternate exists, a mistrial must be declared.
Buford Inquiry: A focused, private questioning of a juror when there is reason to suspect they may be biased or otherwise unqualified. The inquiry must be “probing and tactful,” aimed at determining impartiality without improperly prying into the details of deliberations.
Abuse of Discretion Standard: On appeal, the question is not whether the appellate judges would have made the same decision, but whether the trial judge’s decision was so unreasonable, arbitrary, or unsupported by the record that it falls outside the allowable range of choices.
Implicit Bias: Unconscious stereotypes or assumptions about particular groups (e.g., along racial lines) that can influence decisions and perceptions without a person’s conscious awareness. The dissent emphasizes that implicit bias can affect juror decision‑making even when jurors deny being biased.
CPL 330.30 Motion: A post‑verdict motion in New York criminal cases asking the trial court to set aside the verdict due to newly discovered evidence, juror misconduct, or legal error.
Preservation: A party must timely object or request a specific remedy in order to raise an issue on appeal. Failure to do so usually means the appellate court will not consider that issue.
Weight of the Evidence Review: A special Appellate Division function in New York allowing that court to reweigh the evidence and set aside a verdict even if it is legally sufficient. The Court of Appeals does not reweigh evidence; it only ensures the correct legal standard was applied.

VI. Conclusion

People v. Wiggins sits at the intersection of two powerful currents in modern criminal law: a renewed attention to racial bias in jury decision‑making and a longstanding tradition of deference to trial judges in managing juries and preserving the secrecy of deliberations.

The majority affirms the conviction, holding that:

Allegations of racial bias by one juror against others require a careful, tactful inquiry, but do not automatically compel either removal or mistrial;
Where the alleged racist comment is contested and can plausibly be understood as part of an evidentiary discussion about identification, the trial court may reasonably conclude that bias has not been shown to a degree requiring intervention; and
Appellate courts will rarely disturb such context‑bound judgments absent clear abuse of discretion, especially where defense counsel has limited the remedial options pursued at trial.

The dissent, by contrast, would give greater weight to the structural risks of racial bias, especially in a setting where the only juror of color reports being personally insulted and outnumbered by white jurors making racially charged comments. It would treat such a scenario as incompatible with the guarantee of an impartial jury.

Going forward, Wiggins will likely be cited for the proposition that:

“The mere fact that race entered the jury’s deliberations does not establish that racial bias infected their verdict,” and
Trial courts retain broad discretion—bounded by Buford and CPL 270.35—when faced with allegations of racial remarks in the jury room.

At the same time, the dissent and the surrounding context of equal‑justice reforms may continue to press New York courts to refine how they address implicit and explicit bias in the jury system. The tension between finality and fairness, and between deference and robust protection against racial prejudice, remains unresolved—and Wiggins is likely to be a key reference point in that ongoing debate.