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709 KB
Extraction Summary
9
People
3
Organizations
0
Locations
1
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
709 KB
Summary
This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, presents an argument on behalf of Ms. Maxwell regarding juror misconduct. It contends that the government's view—that Maxwell must carry a heavier burden of proof because Juror No. 50 was untruthful during jury selection—is unfair and incorrect. The argument cites legal precedents, including McDonough and United States v. Stewart, to establish the proper standard for challenging a juror based on false voir dire responses.
People (9)
| Name | Role | Context |
|---|---|---|
| McDonough |
Party in the case McDonough, cited as legal precedent.
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| Blackmun, J. | Justice |
Mentioned as concurring in the McDonough case.
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| Smith |
Party in the case Smith, cited as legal precedent.
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| O’Connor, J. | Justice |
Mentioned as concurring in the McDonough case.
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| Langford |
Party in a case, cited as legal precedent.
|
|
| Juror No. 50 | Juror |
A juror in Ms. Maxwell's trial who allegedly did not answer questions truthfully.
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| Ms. Maxwell | Defendant/Movant |
A party in the current legal case, arguing about the burden of proof regarding Juror No. 50's alleged dishonesty.
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| Haynes |
Party in the case United States v. Haynes, cited as legal precedent.
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| Stewart |
Party in the case United States v. Stewart, cited as legal precedent.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Supreme Court | government agency |
Implied by citations to "U.S." case reporters (e.g., 464 U.S. at 556-57) and references to Justices Blackmun and O'Co...
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| Second Circuit | government agency |
A U.S. Court of Appeals mentioned as having held a certain view in Langford and in the case United States v. Haynes.
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| The government | government agency |
The opposing party to Ms. Maxwell in the legal case, whose view on the burden of proof is being challenged.
|
Timeline (1 events)
A discussion of the legal standard for challenging a juror for cause based on false statements made during voir dire, in the context of Ms. Maxwell's case regarding Juror No. 50.
Relationships (2)
The document centers on Ms. Maxwell's legal challenge concerning Juror No. 50, who allegedly did not tell the truth during jury selection, thereby preventing Maxwell from challenging him for cause.
The document contrasts Ms. Maxwell's legal position with the government's view on the burden of proof required to challenge a juror's dishonesty.
Key Quotes (2)
"the facts are such that bias is to be inferred."Source
— McDonough case precedent
(Quoted from the McDonough case to describe exceptional circumstances for demonstrating juror bias.)
DOJ-OGR-00009206.jpg
Quote #1
"[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
— United States v. Stewart case precedent
(Quoted as the standard under Second Circuit law for addressing undisclosed juror bias.)
DOJ-OGR-00009206.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,083 characters)
Case 1:20-cr-00330-PAE Document 616 Filed 02/24/22 Page 16 of 32
trial hearing at which the movant has the opportunity to demonstrate actual bias or, in
exceptional circumstances, that the facts are such that bias is to be inferred.” McDonough, 464
U.S. at 556-57 (Blackmun, J., concurring) (citing Smith, 455 U.S. at 215-16; id. at 220-24
(O’Connor, J., concurring)).
exceptional circumstances, that the facts are such that bias is to be inferred.” McDonough, 464
U.S. at 556-57 (Blackmun, J., concurring) (citing Smith, 455 U.S. at 215-16; id. at 220-24
(O’Connor, J., concurring)).
This is the only fair reading of McDonough and Langford, and it is only conclusion the
Sixth Amendment permits. Imagine the counterfactual scenario in which Juror No. 50 truthfully
answered Questions 25 and 48. If Ms. Maxwell had challenged Juror No. 50 for cause and this
Court had denied that challenge, Ms. Maxwell would be able to raise the issue in a new trial
motion and, if that were denied, on appeal. In the new trial motion or on appeal, Ms. Maxwell’s
only burden would be to prove that Juror No. 50 was impliedly, inferably, or actually biased.
E.g., United States v. Haynes, 398 F.2d 980, 983 (2d Cir. 1968) (new trial required when a
deliberating juror is actually or impliedly biased). She would not have to prove any inadvertent
falsehoods or deceit by Juror No. 50.
Sixth Amendment permits. Imagine the counterfactual scenario in which Juror No. 50 truthfully
answered Questions 25 and 48. If Ms. Maxwell had challenged Juror No. 50 for cause and this
Court had denied that challenge, Ms. Maxwell would be able to raise the issue in a new trial
motion and, if that were denied, on appeal. In the new trial motion or on appeal, Ms. Maxwell’s
only burden would be to prove that Juror No. 50 was impliedly, inferably, or actually biased.
E.g., United States v. Haynes, 398 F.2d 980, 983 (2d Cir. 1968) (new trial required when a
deliberating juror is actually or impliedly biased). She would not have to prove any inadvertent
falsehoods or deceit by Juror No. 50.
In the government’s view, however, Ms. Maxwell must carry a heavier burden than she
otherwise would because Juror No. 50 did not tell the truth. That neither makes sense nor is fair.
Ms. Maxwell should not be punished because Juror No. 50 did not tell the truth, particularly
when Ms. Maxwell could not have challenged Juror No. 50 for cause at the time precisely
because he did not tell the truth and she lacked any ability to question the juror.
otherwise would because Juror No. 50 did not tell the truth. That neither makes sense nor is fair.
Ms. Maxwell should not be punished because Juror No. 50 did not tell the truth, particularly
when Ms. Maxwell could not have challenged Juror No. 50 for cause at the time precisely
because he did not tell the truth and she lacked any ability to question the juror.
Fortunately, the government’s view is wrong, as five justices in McDonough made clear
and the Second Circuit held in Langford. Under Second Circuit law, as the Court held in United
States v. Stewart, “[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,
and the Second Circuit held in Langford. Under Second Circuit law, as the Court held in United
States v. Stewart, “[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,
11
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