DOJ-OGR-00014868.jpg
614 KB
Extraction Summary
4
People
5
Organizations
1
Locations
4
Events
0
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
614 KB
Summary
This legal document discusses the application of Rule 33 motions concerning juror responses during voir dire, referencing the McDonough standard. It details the District Court's finding that Juror 50's erroneous responses were not deliberately incorrect and that Maxwell did not challenge other jurors with similar disclosures. The document cites several legal precedents, including United States v. Gambino and McDonough Power Equipment, Inc. v. Greenwood, to support its legal arguments regarding the standard for overturning trial results based on juror honesty.
Organizations (5)
| Name | Type | Context |
|---|---|---|
| McDonough Power Equipment, Inc. | company |
Party in the case McDonough Power Equipment, Inc. v. Greenwood, which governs Rule 33 motions
|
| District Court | government agency |
Applied the McDonough standard and made findings regarding Juror 50
|
| United States | government agency |
Party in the case United States v. Gambino
|
| 2d Cir. | government agency |
Second Circuit Court of Appeals, cited in United States v. Gambino
|
| Supreme Court | government agency |
Reminds about the standard for invalidating trial results based on juror responses
|
Timeline (4 events)
1984
McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984) cited as legal precedent.
1995
United States v. Gambino, 59 F.3d 353, 364 (2d Cir. 1995) cited as legal precedent.
2d Cir.
A Rule 33 motion based on a juror’s alleged erroneous response during voir dire, governed by McDonough Power Equipment, Inc. v. Greenwood.
The District Court applied the McDonough standard, found Juror 50’s testimony credible, and determined that Juror 50’s erroneous responses during voir dire were not deliberately incorrect.
Locations (1)
| Location | Context |
|---|---|
|
Refers to the Second Circuit Court of Appeals, cited in United States v. Gambino
|
Key Quotes (4)
"must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause."Source
DOJ-OGR-00014868.jpg
Quote #1
"not deliberately incorrect"Source
— District Court
(District Court's finding regarding Juror 50's voir dire responses)
DOJ-OGR-00014868.jpg
Quote #2
"he would not have been struck for cause if he had provided accurate responses to the questionnaire."Source
— District Court
(District Court's finding regarding Juror 50's voir dire responses)
DOJ-OGR-00014868.jpg
Quote #3
"[t]o invalidate the result of a [ ] trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give."Source
— Supreme Court
(A general principle regarding juror responses and the invalidation of trial results)
DOJ-OGR-00014868.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,540 characters)
Case 1:20-cr-00330-PAE Document 1781 Filed 12/02/24 Page 18 of 26
broad discretion to decide Rule 33 motions based upon its evaluation
of the proof produced” and is shown deference on appeal.30
of the proof produced” and is shown deference on appeal.30
A Rule 33 motion based on a juror’s alleged erroneous response
during voir dire is governed by McDonough Power Equipment, Inc. v.
Greenwood.31 Under McDonough, a party seeking a new trial “must first
demonstrate that a juror failed to answer honestly a material question
on voir dire, and then further show that a correct response would have
provided a valid basis for a challenge for cause.”32
during voir dire is governed by McDonough Power Equipment, Inc. v.
Greenwood.31 Under McDonough, a party seeking a new trial “must first
demonstrate that a juror failed to answer honestly a material question
on voir dire, and then further show that a correct response would have
provided a valid basis for a challenge for cause.”32
The District Court applied the McDonough standard, found Juror
50’s testimony credible, and determined that Juror 50’s erroneous
responses during voir dire were “not deliberately incorrect” and that
“he would not have been struck for cause if he had provided accurate
responses to the questionnaire.”33 In fact, as the District Court noted,
Maxwell did not challenge the inclusion of other jurors who disclosed
past experience with sexual abuse, assault, or harassment. This is
50’s testimony credible, and determined that Juror 50’s erroneous
responses during voir dire were “not deliberately incorrect” and that
“he would not have been struck for cause if he had provided accurate
responses to the questionnaire.”33 In fact, as the District Court noted,
Maxwell did not challenge the inclusion of other jurors who disclosed
past experience with sexual abuse, assault, or harassment. This is
30 United States v. Gambino, 59 F.3d 353, 364 (2d Cir. 1995) (citation and internal quotation
marks omitted).
31 464 U.S. 548 (1984).
32 Id. at 556.
33 A-340 (emphasis added). The Supreme Court reminds us that “[t]o invalidate the result
of a [ ] trial because of a juror’s mistaken, though honest response to a question, is to insist
on something closer to perfection than our judicial system can be expected to give.”
McDonough, 464 U.S. at 555.
marks omitted).
31 464 U.S. 548 (1984).
32 Id. at 556.
33 A-340 (emphasis added). The Supreme Court reminds us that “[t]o invalidate the result
of a [ ] trial because of a juror’s mistaken, though honest response to a question, is to insist
on something closer to perfection than our judicial system can be expected to give.”
McDonough, 464 U.S. at 555.
18
DOJ-OGR-00014868
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document