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679 KB
Extraction Summary
4
People
2
Organizations
0
Locations
2
Events
0
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
679 KB
Summary
This document is a page from a legal filing, dated June 29, 2023, that outlines the legal framework for challenging jurors for cause. It details the different types of juror bias—actual, implied, and inferable—and cites several U.S. court cases to define these categories and establish the criteria for their application. The text also briefly mentions the possibility of a post-verdict hearing for juror misconduct.
People (4)
| Name | Role | Context |
|---|---|---|
| Greenwood | Party in a legal case |
Mentioned in the case citation 'Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984)'.
|
| Stewart | Party in a legal case |
Mentioned in the case citation 'United States v. Stewart, 433 F.3d 273, 304 (2d Cir. 2006)'.
|
| Torres | Party in a legal case |
Mentioned in the case citation 'United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997)'.
|
| Baker | Party in a legal case |
Mentioned in the case citation 'United States v. Baker, 899 F.3d 123, 130 (2d Cir. 2018)'.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Power Equip., Inc. | company |
Party in the legal case 'Power Equip., Inc. v. Greenwood'.
|
| United States | government agency |
Party in the legal cases 'United States v. Stewart', 'United States v. Torres', and 'United States v. Baker'.
|
Timeline (2 events)
Key Quotes (8)
"that a correct response would have provided a valid basis for a challenge for cause."Source
— Power Equip., Inc. v. Greenwood
(Describing the second part of a two-prong test for challenging a juror.)
DOJ-OGR-00021717.jpg
Quote #1
"narrowly specified, provable and legally cognizable bases."Source
— United States v. Torres
(Stating the grounds on which a party may challenge a juror for cause.)
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Quote #2
"Actual bias is bias in fact—the existence of a state of mind that leads to an inference that the person will not act with entire impartiality."Source
— United States v. Torres
(Defining 'actual bias' as one of the categories for a challenge for cause.)
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Quote #3
"bias conclusively presumed as a matter of law."Source
— United States v. Torres
(Defining 'implied bias' or 'presumed bias'.)
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Quote #4
"reserved for ‘exceptional situations,’"Source
— This Court (referencing United States v. Torres)
(Describing the narrow application of the 'implied bias' category.)
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Quote #5
"are related to the parties"Source
— United States v. Torres
(Providing an example of a circumstance for implied bias.)
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Quote #6
"were victims of the alleged crime itself."Source
— United States v. Torres
(Providing another example of a circumstance for implied bias.)
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Quote #7
"[b]ias may be inferred when a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias."Source
— United States v. Torres
(Defining 'inferable bias' and the conditions under which it may be found.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (1,796 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page70 of 93
57
Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556
(1984). Second, the party must show “that a correct re-
sponse would have provided a valid basis for a chal-
lenge for cause.” Id. To satisfy this prong, a court must
determine whether, if the juror had answered truth-
fully, it would have granted a hypothetical strike for
cause. United States v. Stewart, 433 F.3d 273, 304 (2d
Cir. 2006).
A party may challenge a juror for cause based only
on “narrowly specified, provable and legally cognizable
bases.” United States v. Torres, 128 F.3d 38, 43 (2d Cir.
1997). In the context of voir dire, challenges for cause
generally fall into one of three “limited” categories: ac-
tual bias, implied bias, or inferable bias. Id. “Actual
bias is bias in fact—the existence of a state of mind
that leads to an inference that the person will not act
with entire impartiality.” Id. Implied bias, also called
“presumed bias,” is “bias conclusively presumed as a
matter of law.” Id. at 45. This Court has emphasized
that this category is “narrow,” and “reserved for ‘ex-
ceptional situations,’” generally meaning circum-
stances in which jurors “are related to the parties” or
“were victims of the alleged crime itself.” Id. at 45-46.
Finally, “[b]ias may be inferred when a juror discloses
a fact that bespeaks a risk of partiality sufficiently sig-
nificant to warrant granting the trial judge discretion
to excuse the juror for cause, but not so great as to
make mandatory a presumption of bias.” Id. at 46-47.
Where there are concrete allegations of juror mis-
conduct, a court may conduct a post-verdict hearing.
See United States v. Baker, 899 F.3d 123, 130 (2d Cir.
2018). The inquiry “should be limited to only what is
(1984). Second, the party must show “that a correct re-
sponse would have provided a valid basis for a chal-
lenge for cause.” Id. To satisfy this prong, a court must
determine whether, if the juror had answered truth-
fully, it would have granted a hypothetical strike for
cause. United States v. Stewart, 433 F.3d 273, 304 (2d
Cir. 2006).
A party may challenge a juror for cause based only
on “narrowly specified, provable and legally cognizable
bases.” United States v. Torres, 128 F.3d 38, 43 (2d Cir.
1997). In the context of voir dire, challenges for cause
generally fall into one of three “limited” categories: ac-
tual bias, implied bias, or inferable bias. Id. “Actual
bias is bias in fact—the existence of a state of mind
that leads to an inference that the person will not act
with entire impartiality.” Id. Implied bias, also called
“presumed bias,” is “bias conclusively presumed as a
matter of law.” Id. at 45. This Court has emphasized
that this category is “narrow,” and “reserved for ‘ex-
ceptional situations,’” generally meaning circum-
stances in which jurors “are related to the parties” or
“were victims of the alleged crime itself.” Id. at 45-46.
Finally, “[b]ias may be inferred when a juror discloses
a fact that bespeaks a risk of partiality sufficiently sig-
nificant to warrant granting the trial judge discretion
to excuse the juror for cause, but not so great as to
make mandatory a presumption of bias.” Id. at 46-47.
Where there are concrete allegations of juror mis-
conduct, a court may conduct a post-verdict hearing.
See United States v. Baker, 899 F.3d 123, 130 (2d Cir.
2018). The inquiry “should be limited to only what is
DOJ-OGR-00021717
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