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774 KB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
774 KB
Summary
This legal document is a portion of a motion filed on behalf of Ms. Maxwell, arguing that the court should investigate potential misconduct by two jurors. The motion contends that Rule of Evidence 606(b) does not bar an inquiry into Juror No. 50's alleged bias and false statements, and that a second juror who alerted the New York Times about being a victim of childhood sexual abuse should also be questioned. The argument is that failing to investigate these matters violates Ms. Maxwell's constitutional rights to a fair and impartial jury.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the motion, arguing for an inquiry into juror misconduct due to potential bias, which she claims violates ...
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| Juror No. 50 | Juror |
A juror whose bias is being questioned, alleged to have provided false answers during voir dire and made statements t...
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| Pena-Rodriguez |
Mentioned in the case citation 'Pena-Rodriguez v. Colorado'.
|
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| Warger |
Mentioned in the case citation 'Warger v. Shauers'.
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| Shauers |
Mentioned in the case citation 'Warger v. Shauers'.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| New York Times | company |
A second juror alerted the New York Times about their experience as a victim of childhood sexual abuse.
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| U.S. Const. | government agency |
Cited in reference to Ms. Maxwell's constitutional rights to due process and confrontation (amendments V, VI).
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Timeline (2 events)
Motion by Ms. Maxwell to conduct an inquiry into juror bias and misconduct.
Court
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the case citation 'Pena-Rodriguez v. Colorado'.
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Relationships (2)
The document details Ms. Maxwell's motion to investigate Juror No. 50 for alleged bias and misconduct, which she claims violated her right to a fair trial.
The document argues that a second, unnamed juror should also be questioned for failing to disclose their history of childhood sexual abuse, which is relevant to Ms. Maxwell's case.
Key Quotes (1)
"[t]here may be cases of juror bias so extreme that, almost by definition, the jury trial right has been abridged. If and when such a case arises, the Court can consider whether the usual safeguards are or are not sufficient to protect the integrity of the process. We need not consider the question, however, for those facts are not presented here."Source
— Warger v. Shauers, 574 U.S. 40, 49 & n.3
(Quoted in a footnote to recognize that there are exceptions to Rule 606(b) which bars inquiry into jury deliberations.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (2,358 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 28 of 32
For all the reasons given in the motion, Rule of Evidence 606(b) poses no bar to the
inquiry this Court should conduct on Ms. Maxwell’s motion, primarily because Ms. Maxwell
possesses evidence from external to the deliberations to substantiate Juror No. 50’s bias. To the
extent the Rule might apply as a bar to limit certain questions, it violates Ms. Maxwell’s
constitutional rights to due process and to confrontation as applied to her. U.S. Const. amends.
V, VI; cf. Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (finding the no-impeachment rule
of 606(b) unconstitutional as applied to juror statements indicating racial bias). The Rules of
Evidence cannot constitutionally prevent Ms. Maxwell from proving juror misconduct and
vindicating her right to a fair and impartial jury.11
inquiry this Court should conduct on Ms. Maxwell’s motion, primarily because Ms. Maxwell
possesses evidence from external to the deliberations to substantiate Juror No. 50’s bias. To the
extent the Rule might apply as a bar to limit certain questions, it violates Ms. Maxwell’s
constitutional rights to due process and to confrontation as applied to her. U.S. Const. amends.
V, VI; cf. Pena-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (finding the no-impeachment rule
of 606(b) unconstitutional as applied to juror statements indicating racial bias). The Rules of
Evidence cannot constitutionally prevent Ms. Maxwell from proving juror misconduct and
vindicating her right to a fair and impartial jury.11
3. The Additional Biased Juror Should Be Questioned
As detailed in the motion at 21, a second juror has alerted the New York Times that they
too had deliberated on the case and were the victim of childhood sexual abuse. That juror whose
identity is currently unknown also failed to disclose their victimhood in response to Question
48.12 The government would like to bury its head in the sand and deprive Ms. Maxwell of the
too had deliberated on the case and were the victim of childhood sexual abuse. That juror whose
identity is currently unknown also failed to disclose their victimhood in response to Question
48.12 The government would like to bury its head in the sand and deprive Ms. Maxwell of the
11 See also Warger v. Shauers, 574 U.S. 40, 49 & n.3 (holding, before Pena-Rodriguez
was decided, that Rule 606(b) bars inquiry to “deliberations evidence” when seeking a new trial
based on juror false statements during voir dire but recognizing that “[t]here may be cases of
juror bias so extreme that, almost by definition, the jury trial right has been abridged. If and
when such a case arises, the Court can consider whether the usual safeguards are or are not
sufficient to protect the integrity of the process. We need not consider the question, however, for
those facts are not presented here.”).
was decided, that Rule 606(b) bars inquiry to “deliberations evidence” when seeking a new trial
based on juror false statements during voir dire but recognizing that “[t]here may be cases of
juror bias so extreme that, almost by definition, the jury trial right has been abridged. If and
when such a case arises, the Court can consider whether the usual safeguards are or are not
sufficient to protect the integrity of the process. We need not consider the question, however, for
those facts are not presented here.”).
Warger doesn’t control here, though, if only because it was a civil and not a criminal
case. Moreover, in this case, Juror No. 50’s statements admitting to having provided false
answers during voir dire are statements he personally made to the media and on social media.
Those statements are not “deliberations evidence” and not subject to Rule 606(b) in any case,
even under Warger.
case. Moreover, in this case, Juror No. 50’s statements admitting to having provided false
answers during voir dire are statements he personally made to the media and on social media.
Those statements are not “deliberations evidence” and not subject to Rule 606(b) in any case,
even under Warger.
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