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632 KB
Extraction Summary
7
People
2
Organizations
0
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
632 KB
Summary
This document is a page from a legal opinion (Case 22-1426) dated September 17, 2024, concerning the appeal of a District Court's decision. The appellant, Maxwell, argues for a new trial on the grounds that Juror 50 was dishonest on a jury questionnaire regarding a history of sexual abuse. The text outlines the high legal standard of "abuse of discretion" required to overturn the lower court's ruling, emphasizing that new trials are granted only sparingly and in extraordinary circumstances.
People (7)
| Name | Role | Context |
|---|---|---|
| Maxwell | Appellant/Defendant |
Mentioned as the individual whose motion for a new trial was denied by the District Court.
|
| Juror 50 | Juror |
The juror who allegedly failed to accurately respond to a jury questionnaire, which is the basis for Maxwell's motion.
|
| Rivas | Litigant |
Mentioned in the case citation 'Rivas v. Brattesani'.
|
| Brattesani | Litigant |
Mentioned in the case citation 'Rivas v. Brattesani'.
|
| Ferguson | Litigant |
Mentioned in the case citation 'United States v. Ferguson'.
|
| Sims | Litigant |
Mentioned in the case citation 'In re Sims'.
|
| Moon | Litigant |
Mentioned in the case citation 'United States v. Moon'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| District Court | judicial body |
The court that denied Maxwell's motion for a new trial.
|
| United States | government |
Mentioned as a party in the case citations 'United States v. Ferguson' and 'United States v. Moon'.
|
Timeline (2 events)
Maxwell's motion for a new trial was denied by the District Court following a special evidentiary hearing.
District Court
Relationships (2)
Maxwell's motion for a new trial is based on the contention that Juror 50 failed to accurately answer questions during jury selection.
The District Court denied Maxwell's motion for a new trial, and this document is reviewing that decision.
Key Quotes (6)
"haul jurors in after they have reached a verdict in order to probe for potential instances of bias, misconduct or extraneous influences."Source
— Court (citing United States v. Moon)
(Describing the court's reluctance to question jurors after a verdict has been reached.)
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Quote #1
"vacate any judgment and grant a new trial if the interest of justice so requires,"Source
— Fed. R. Crim. P. 33(a)
(Stating the legal standard for when a court can grant a new trial.)
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Quote #2
"sparingly"Source
— Court (interpreting Fed. R. Crim. P. 33(a))
(Describing how often courts should grant new trials.)
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Quote #3
"the most extraordinary circumstances."Source
— Court (interpreting Fed. R. Crim. P. 33(a))
(Describing the conditions under which a new trial should be granted.)
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Quote #4
"[W]e are mindful that a judge has not abused her discretion simply because she has made a different decision than we would have made in the first instance."Source
— Court (citing Rivas v. Brattesani)
(Explaining the standard of review for 'abuse of discretion'.)
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Quote #5
"a decision that cannot be located within the range of permissible decisions."Source
— Court (citing In re Sims)
(Providing a definition for what constitutes an 'abuse of discretion'.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,737 characters)
Case 22-1426, Document 109-1, 09/17/2024, 3634097, Page17 of 26
3. The District Court Did Not Abuse Its Discretion in Denying Maxwell’s Motion for a New Trial
Maxwell contends that she was deprived of her constitutional right to a fair and impartial jury because Juror 50 failed to accurately respond to several questions related to his history of sexual abuse as part of the jury questionnaire during jury selection. Following a special evidentiary hearing, the District Court denied Maxwell’s motion for a new trial.
We review a District Court’s denial of a motion for a new trial for abuse of discretion.27 We have been extremely reluctant to “haul jurors in after they have reached a verdict in order to probe for potential instances of bias, misconduct or extraneous influences.”28 While courts can “vacate any judgment and grant a new trial if the interest of justice so requires,” Fed. R. Crim. P. 33(a), they should do so “sparingly” and only in “the most extraordinary circumstances.”29 A district court “has
27 See Rivas v. Brattesani, 94 F.3d 802, 807 (2d Cir. 1996). “[W]e are mindful that a judge has not abused her discretion simply because she has made a different decision than we would have made in the first instance.” United States v. Ferguson, 246 F.3d 129, 133 (2d Cir. 2001). We have repeatedly explained that the term of art “abuse of discretion” includes errors of law, a clearly erroneous assessment of the evidence, or “a decision that cannot be located within the range of permissible decisions.” In re Sims, 534 F.3d 117, 132 (2d Cir. 2008) (citation and internal quotation marks omitted).
28 United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983).
29 Ferguson, 246 F.3d at 134.
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