SAN FRANCISCO (CN) - Errors by a lower court were significant enough to warrant a new trial for a Pennsylvania man convicted over a woman's death in the Nevada desert, a Ninth Circuit panel decided Friday

A jury convicted John Matthew Chapman in 2024 after an eight-day trial, finding him guilty of kidnapping resulting in death.

Serving a life term, Chapman appealed, arguing the judge improperly allowed his confession to reach jurors and wrongly denied a postverdict motion for acquittal.

The appeals panel affirmed those decisions by the lower court. It also broke new legal ground for the Ninth Circuit, finding that "holding" - an element of the kidnapping charge - can be through deception and just not physical restraint.

Nonetheless, they found the trial judge made key errors that warranted a vacation of Chapman's conviction. They ordered the case remanded for a new trial.

The panel noted the trial judge had delivered an Allen charge. The controversial practice - which stems from the 1896 Supreme Court case Allen v. United States - is intended to encourage a deadlocked jury to deliberate further and reach a unanimous verdict. But since jurors are required to reach decisions based on their own reasoning, critics say Allen charges can have the effect of pressuring jurors into making a decision they otherwise would not have. Many states have even banned the practice.

The judge had failed to tell the parties about two jury notes he received that revealed juror vote tallies, the panel said, and had also made coercive comments to a juror.

Writing for the panel, U.S. Circuit Judge Ronald Gould noted the jury quickly reached a verdict after the charge.

"After being deadlocked for two days during deliberations, the jury spent only 37 minutes deliberating after the district court's charge before swiftly returning with a unanimous guilty verdict," the Bill Clinton appointee wrote. "We have repeatedly held that a short time frame for deliberations after an Allen charge indicates coercion."

Authorities accused Chapman of driving his girlfriend from Pennsylvania to Las Vegas under the guise of a vacation and potentially looking for a house to buy. They said he tied her up and taped her mouth and nose, purportedly for a bondage photo shoot, before watching her die and leaving her body in the Nevada desert.

Pointing to Ninth Circuit precedent and the juror notes about tallies, Gould wrote that reversal is required if a judge gives an Allen charge despite knowing how jurors were voting. That's because holdout jurors might think the judge directed the charge at them.

The panel also found fault with the lower court's intense questioning of a juror who asked to be replaced.

The trial judge asked the juror if they couldn't follow instructions, Gould wrote. Since Chapman argued he had autism and other mental health diagnoses, the juror said they were simply following the evidence. The juror referenced a doctor's testimony in the trial about how autistic people sometimes can't grasp nonverbal communication. The judge, however, called it irrelevant.

"After this exchange, Juror Number 11 thanked the court, and the court repeated that Juror Number 11 would 'have to surrender that opinion' and would have to base the verdict decision 'on the evidence and not on something you remember some doctor said,'" Gould wrote.

The guilty verdict came 37 minutes later.

The appeals panel also addressed whether Chapman knowingly and willingly waived his Miranda rights when speaking with law enforcement, ultimately finding that he had indeed waived them.

"Chapman brought up his Miranda rights several times before they were read to him, and Chapman had completed a prior federal sentence for federal wire fraud and identity theft charges," Gould wrote. "He was clearly not without 'prior experience with the criminal justice system.'"

The panel found that Chapman's diagnoses didn't affect his ability to understand Miranda.

"Chapman explained his disabilities in detail, assured the detectives he understood what was happening while he was being questioned and knew details about the consequences of the crime to which he admitted," Gould wrote. "These circumstances do not persuade us that Chapman's will was overborne by the detectives or that the circumstances otherwise show that his statements were involuntary."

The Office of the Federal Public Defender of Nevada declined comment. The U.S. Attorney's Office for the District of Nevada couldn't be reached for comment.

The appeals panel was rounded out by U.S. Circuit Judges Jacqueline Nguyen, a Barack Obama appointee, and Mark Bennett, appointed by Donald Trump.

Source: Courthouse News Service