DOJ-OGR-00009113.jpg
765 KB
Extraction Summary
10
People
3
Organizations
1
Locations
4
Events
3
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
765 KB
Summary
This legal document argues that Juror 50 should have been struck for cause due to bias revealed in press statements. It cites legal precedent, primarily the Supreme Court's decision in McDonough and the Second Circuit's test in United States v. Stewart, to assert that a new trial can be granted based on a juror's inaccurate voir dire response, even if the response was not deliberately dishonest. The document contends that the key is whether the juror was actually biased and whether a correct answer would have provided grounds for a challenge.
People (10)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
The subject of the legal argument, whose press statements allegedly reveal bias, making them eligible to be struck fo...
|
| Blackmun, J. | Justice |
A Supreme Court Justice who wrote a concurring opinion in McDonough, cited for the proposition that a court can order...
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| Stevens | Justice |
A Supreme Court Justice with whom Justice Blackmun concurred in the McDonough case.
|
| O'Connor, JJ. | Justice |
A Supreme Court Justice with whom Justice Blackmun concurred in the McDonough case.
|
| Brennan, J. | Justice |
A Supreme Court Justice who wrote a concurring opinion in McDonough, cited for the idea that an incorrect answer may ...
|
| Marshall, J. | Justice |
A Supreme Court Justice with whom Justice Brennan concurred in the McDonough case.
|
| Stewart | Party in a cited case |
Mentioned in the case citation United States v. Stewart.
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| Strickler | Party in a cited case |
Mentioned in the case citation Strickler v. Greene.
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| Greene | Party in a cited case |
Mentioned in the case citation Strickler v. Greene.
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| Brady | Party in a cited case |
Mentioned in the context of the Brady rule regarding inadvertent nondisclosure of evidence.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Supreme Court | government agency |
Cited for its decision in McDonough, which provides the starting point for analyzing whether a new trial is required ...
|
| The Second Circuit | government agency |
Cited for its test regarding undisclosed juror bias, as framed in the case United States v. Stewart.
|
| DOJ | government agency |
Appears in the footer as part of a document identifier (DOJ-OGR-00009113).
|
Timeline (4 events)
The Supreme Court's decision in the McDonough case, establishing a test for granting a new trial based on a juror's voir dire answers.
Supreme Court
Locations (1)
| Location | Context |
|---|---|
|
Referenced in case citations such as '464 U.S. at 556' and 'United States v. Stewart'.
|
Relationships (3)
Justice Blackmun concurred with Justice Stevens in the McDonough case.
Justice Blackmun concurred with Justice O'Connor in the McDonough case.
Justice Brennan concurred with Justice Marshall in the McDonough case.
Key Quotes (6)
"[w]e hold that to obtain a new trial in such a situation, a party 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
— Supreme Court (plurality opinion in McDonough)
(Stating the initial test for when a new trial is required due to a juror's answer in voir dire.)
DOJ-OGR-00009113.jpg
Quote #1
"honest"Source
— Supreme Court (plurality opinion in McDonough)
(Used to describe the juror's state of mind in the plurality opinion, which the document argues is not the sole determining factor.)
DOJ-OGR-00009113.jpg
Quote #2
"regardless of whether a juror’s answer is honest or dishonest"Source
— Justice Blackmun (concurring opinion)
(Cited to support the argument that a court can order a new trial even if the juror's inaccurate answer was not deliberately dishonest.)
DOJ-OGR-00009113.jpg
Quote #3
"a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror’s voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause."Source
— The Second Circuit (in United States v. Stewart)
(The test framed by the Second Circuit for addressing undisclosed juror bias.)
DOJ-OGR-00009113.jpg
Quote #4
"False"Source
— The Second Circuit (in United States v. Stewart)
(The document clarifies that in this legal context, 'False' means inaccurate or materially misleading, not necessarily deliberately untruthful.)
DOJ-OGR-00009113.jpg
Quote #5
"[U]nder Brady an inadvertent nondisclosure has the same impact on the fairness of the proceedings as deliberate concealment. ‘If the suppression of evidence results in constitutional error, it is because of the character of the evidence, not the character of the prosecutor.’"Source
— Supreme Court (in Strickler v. Greene)
(Cited in a footnote to support the broader legal principle that an error in criminal law does not need to be deliberate to have consequences.)
DOJ-OGR-00009113.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,309 characters)
Case 1:20-cr-00330-PAE Document 614 Filed 02/24/22 Page 6 of 12
II. JUROR 50’s PRESS STATEMENTS REVEAL THAT HE WAS BIASED AND SHOULD HAVE BEEN STRUCK FOR CAUSE
Where a juror’s inaccurate answer during voir dire is revealed, the starting point for analyzing whether a new trial is required is the Supreme Court’s decision in McDonough. The Court’s plurality opinion states: “[w]e hold that to obtain a new trial in such a situation, a party 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.” 464 U.S. at 556. However, the plurality’s focus on whether the juror was “honest” does not mean that an inaccurate answer, though not given deliberately, cannot suffice to undermine the integrity of the verdict. Five Justices of the Court, in two concurring opinions, agreed that a court may vacate a conviction based upon a juror’s erroneous answer if, under all the circumstances, the juror is shown to have been biased. See id. at 556 (explaining that a court can order a new trial “regardless of whether a juror’s answer is honest or dishonest”) (Blackmun, J., concurring with Stevens and O’Connor, JJ.); id. at 557-59 (incorrect answer may be sufficient) (Brennan, J., concurring with Marshall, J.).⁶
The Second Circuit has framed the test: “a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror’s voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause.” United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006). “False” in this context means inaccurate or materially misleading, not necessarily deliberately untruthful; any other rule would unacceptably dilute the
⁶ The rule that error need not be deliberate is followed in other contexts in criminal law. Cf. Strickler v. Greene, 527 U.S. 263, 288 (1999) (“[U]nder Brady an inadvertent nondisclosure has the same impact on the fairness of the proceedings as deliberate concealment. ‘If the suppression of evidence results in constitutional error, it is because of the character of the evidence, not the character of the prosecutor.’”) (internal citation omitted).
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