Sunday, 12 August 2012

The Anglo-American Jury and Japanese Criminal Justice


      The Japanese government is in the process of transforming the nation’s criminal procedure from its traditional system whereby a judge unilaterally determines verdict and sentence to a new system whereby such decisions are to be made by a collective of a judge and jury, or ‘Saiban-in.’ The new system, which will take effect in 2008, is believed by many to be a middle ground between the Franco-German juryless system and the Anglo-American system, in which a group of ordinary citizens determine the fate of a defendant without judicial interference. However, the proposed procedural change will without doubt render the jury powerless and continue the de-facto monopoly that judges have when it comes to making judgments in criminal cases, as they will retain tremendous influence over the decisions of the jury. The establishment of a working jury system has the potential to bring about numerous benefits for the Japanese government; assuring that the decisions rendered in criminal cases are made in accord with democratic precepts, encouraging civic participation in government, and restoring public trust in the judiciary. Accordingly, it would be advantageous for Japan if it were to wholeheartedly adopt the Anglo-American jury system so as to provide criminal defendants with a fair trial and to promote civil involvement in judicial proceedings.
A plethora of arguments can be made as to why it would be in the best interest of Japan to establish a jury-based system of criminal procedure. Decisions in Japanese criminal trials have traditionally been determined unilaterally by a judge, and many have been reluctant to modify this system. They cite foreign incidents such as the Rodney King case in the United States, where a jury found white police officers to be innocent of a clearly racially motivated heinous crime, to be evidence as to why Japan should not adopt a jury system. However, judges themselves are not any less prone to making mistakes than are juries. When single political actors are enthroned with the ability to make judicial decisions without substantial oversight, they are prone to lackadaisical or purposeful errors in judgment. Two prominent Japanese cases that evidence fallacious judicial decision-making are Government v. Akabori and Government v. Menda; wherein defendants were found guilty of committing murder and were sentenced to extensive prison sentences; only to be released on appeal after spending twenty-five years behind bars. (Wakulat, 2005, 1) These incidents threaten to propagate widespread public distrust of the Japanese criminal justice system and attest to the need for change. (Cho, 1998, 1)
In addition to blatant judicial error, the traditional arrangement of the Japanese criminal justice system is such that judges have tended to decide cases on paper before testimony is rendered. An inextricable bond exists between the judiciary and the prosecutor’s office and police departments. (Asahara, 2004, 1) This is evidenced by the fact that judges often accept law enforcement claims of a defendant’s “voluntary confession” without looking into whether the defendant was coerced into making an admission of guilt (Kiss, 1999, 2). Defendants, whom can be imprisoned for up to twenty-three days without access to attorney representation, are likely to make such confessions under duress; and the processes by which police officers extract them often goes unchecked. (Richardson, 2004, 1) In addition, Japanese judges have tended to trust prosecutors, effectively affixing a “rubber stamp” to their decisions without considering the potential for falsities (Kiss, 1999, 2). This in part has resulted in an unfathomable ninety-nine percent conviction rate of Japanese criminal defendants; which many see as evidence of improper procedure. (Wakulat, 2005, 1) The institution of a jury system will serve to increase scrutiny into the previously unsupervised methods of prosecutors and law enforcement officials. Also, the nature of jury participation affords the justice system with protections that insure that each criminal defendant is given a full and honest opportunity to defend themselves against allegations. The “laymen” that comprise juries do so only temporarily, and as such, are not subject to the scheduling or monetary constraints that have fostered in judges a need for maximizing efficiency and speed. A group of citizens working together to come to decisions as a jury would be perhaps less prone to missing important details, affording them a better appreciation of the facts surrounding a particular case. In addition, as a group of actors working together, jury members can serve an oversight function, and their very appearance will force the judiciary to follow proper procedure at all times. A transition to a jury system will likely serve to strengthen public confidence in an ailing criminal justice system and government.
Some say that the only characteristics juries share is common outrage, stereotypes, and uneducated judgment. In fact, the infamous Rodney King case also pointed out the impact that racial biases can have on the outcome of a jury trial. However, the homogeneity of Japanese society in terms of race, culture, religion and language may reduce the commonly perceived biases associated with jury trials in the West (Kiss, 1999, 7). Opponents of the jury system argue that it is fallacious to assume that a group of uneducated commoners can make well-informed judgments. However, as elite members of society, judges may find themselves distanced from the moirés and customs of the average citizen. By virtue of the scholastic rigor associated with joining the judiciary, judges can become disconnected from Japanese public opinion and sentiment, and are therefore less able to render judgments in accord with contemporaneous societal views. Judges must undergo extensive training and must pass the difficult National Legal Examination before attaining a judicial post, and in effect, their education serves to propagate in themselves elitist viewpoints that do not correspond with those of the general public. (Kiss, 1999, 2) On the other hand, the “ordinary people” that compose juries will render their decisions based on “common sense and human experience;” the knowledge more applicable to understanding the context within which criminal allegations arise (Belli, 1959, 180).
Also, the existence of a jury system encourages civic participation in government. Although many may feel as though their government operates as a foreign entity having little to do with one’s personal involvement, serving on a jury can give each citizen the opportunity to participate in the workings of their government in a truly meaningful way. Some scholars make the assertion that a jury system is a disguised form of “direct democracy,” where each citizen actively participates in the workings of their government. They argue that such a system was never intended to be instituted in Japan due to the obvious coordination process that such a system would propagate. Although the practice of establishing juries resembles “direct democracy” as it existed in Ancient Greece, the commitment each citizen is required to make to the process is limited. Unlike in Ancient Greece, citizens are not asked to vote on every issue that arises and at all times; but rather each individual will take part in the process within a small subset of the total number of cases and within limited amounts of time. In addition to educating the Japanese populace about the strictures of their legal system, serving on a jury will engrain in each participant feelings of interconnectedness to one’s country, thus instilling a sense of nationalism. The jury system will strengthen Japanese democracy and reinforce the notion of “popular sovereignty,” or the understanding that Japan is ruled by its people. (Richardson, 2004, 2) These measures may help restore public trust in the Japanese legal system. In addition to strengthening democracy at home; the establishment of a jury system in Japan may have the potential to encourage and advance the spread of democracy throughout all of Asia. (Myers, 2006, 1) In fact, the recently adopted changes in Japan have already spurned a “ripple effect” in Asia, as South Korea, the Philippines, and even China have begun to reexamine their existing judicial systems (Fukurai, 2005, 1). Clearly the affording of Japanese criminal defendants a jury has significant implications for the development of democracy both at home and abroad.
Japan is also well positioned and amenable to allowing for the change. During the period of Taisho Democracy, the Japanese government experimented with limited jury system whereby the jury was to provide nonbinding guidance to the judge, who would himself make final decisions. (Von Mehren, 1963, 22) Although this system was gradually eliminated with the onset of totalitarianism, the notion of serving on a jury has been accepted and ingrained into the socio-cultural framework of Japanese society. (Fukurai, 2005, 2) Also, in the latter half of the twentieth century, Japanese citizens have become more willing to bring their quarrels to trial than in the past, thus rendering citizen involvement in the court system less of a “foreign” activity (Kiss, 1999, 7). Given the advantages of the jury system discussed above and the mindset of the Japanese citizenry, the time for change is now.
It has thus been determined that Japan has the potential to benefit from restructuring its justice system so as to afford criminal defendants a jury of their peers. However, the recently established “mixed system” must be examined so as to determine its appropriateness given the Japanese socio-cultural context. This system, which is set to be adopted in 2008, will allow for decisions as to verdict and sentence to be made by a panel of six “Saiban-in,” or jury members, and three judges in cases when there is uncertainty as to guilt; and four “Saiban-in” and one judge in those cases where there is no substantial doubt as to guilt (Anderson, 2005, 233). By virtue of its very design, this system has the potential to bias the outcome of a case. The flaws of this system can be prominently seen if one considers the unique strictures of Japanese culture. As a collectivist society, the Japanese often maintain higher levels of trust and subservience to figures of authority than do those in the West. (Kiss, 1999, 5) This cultural difference makes it likely that in Japan, jury members would be unwilling to confront and disagree with judges of higher relative power and authority. In such a system, it would be more likely that jurors would yield to the opinions of judges in an effort to “maintain harmony” and to “avoid confrontation” (Kiss, 1999, 5). For these reasons, the mixed system is unwarranted, and its establishment will merely continue the de-facto monopoly judges have on decision-making power. If the Japanese government is serious about adopting the jury system it must consider instead the Anglo-American model, wherein decision-making capabilities are transferred in their entirety to a jury; absent of judicial interference. In this setup, jury members would be less inclined to yield to the decisions of co-equal jury members than in if they were working under the de-facto authority of a professional judge. (Kiss, 1999, 6) Only without judicial interference in the decision-making process of juries can the Japanese government insure that each criminal defendant is given a fair opportunity to defend himself, face judgment from an impartial point of view, and receive justice as due him.
In conclusion, Japan stands to greatly benefit from infusing a jury system into its criminal procedure. Juries can help to ensure that trials are conducted fairly; break the previously inextricable bond between judges, prosecutors, and police officers; and utilize their collective common sense to garner an understanding of the context surrounding cases so as to come to objective conclusions. The change can also serve to the benefit of the nation, as the newfound civic participation will allow each and every Japanese citizen to feel as though they play an important role in the decision-making processes of their country. This sentiment will encourage the advancement of democracy both at home and in neighboring countries as they bear witness to the benefits of the jury system. As explained in the foregoing arguments, the “mixed system” recently adopted by the Japanese Diet will promulgate a continuance of judicial authority and render the opinions of the jury meaningless. Ensuring that decisions are made fairly and democratically requires the institution of the Anglo-American jury system, whereby judges are to be removed from the decision-making process in their entirety. Without question, the establishment of a full-fledged jury system would serve to the advantage of Japan.


Works Cited:

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