## Facts

- Coy Patrick Crowe was indicted for the capital murder of James Taylor, a deputy sheriff.
- During Crowe’s trial, Taylor’s widow sat at the prosecutor’s counsel table.
- Taylor’s brother testified and identified the woman seated at the prosecutor’s table as Taylor’s wife.
- Crowe objected to Taylor’s widow sitting at counsel table and asked that she be removed.
- During graphic autopsy testimony from the pathologist, Taylor’s widow began crying; Crowe renewed his objection.
- The trial judge held a hearing in chambers about the objection and the widow’s conduct.
- The judge declined to remove Taylor’s widow from the prosecutor’s table but granted Crowe’s request for a short recess so she could compose herself.
- After the recess, no further incidents occurred, and Taylor’s widow conducted herself properly for the remainder of the trial.
- Crowe was convicted and sentenced to death by electrocution.
- On appeal, Crowe argued that allowing Taylor’s widow to sit at counsel table (and her brief crying) violated his constitutional rights by denying him a fair trial.

## Issues

1. Whether permitting the victim’s widow to sit at the prosecutor’s counsel table, and allowing her to remain after a brief emotional reaction during autopsy testimony, denied the defendant a fair trial in violation of constitutional guarantees.

## Decision

- The court affirmed Crowe’s conviction and death sentence.
- The court held the trial judge acted within allowable control of courtroom seating and conduct in permitting the victim’s widow to sit at counsel table.
- The court found no reversible prejudice from the widow’s brief crying, especially where the judge promptly addressed the situation by conducting a chambers hearing and granting a short recess.
- Because the incident was limited, was controlled by the court, and did not recur, the court concluded Crowe was not deprived of a fair trial.

## Legal Principles

- Trial courts have broad discretion to manage courtroom order, including seating arrangements and responses to disruptions.
- A victim’s family member sitting at the prosecutor’s table is not, by itself, a constitutional violation; relief generally requires a showing that the arrangement likely affected the jury’s ability to decide the case fairly.
- Brief, nonrepeating emotional reactions by spectators do not require reversal when the court takes reasonable steps to minimize any effect on the proceedings.
- Appellate relief is not warranted absent a showing that the complained-of courtroom practice probably influenced the verdict or otherwise denied due process.

## Conclusion

The court upheld Crowe’s conviction and death sentence, ruling that the trial judge did not deny Crowe a fair trial by allowing the deputy’s widow to sit with the prosecution and remain there after a short, controlled emotional episode that was addressed with a recess and did not continue.


Crowe v. State, 485 So. 2d 351 (1986)