DOJ-OGR-00009890.jpg
708 KB
Extraction Summary
6
People
3
Organizations
1
Locations
3
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
708 KB
Summary
This legal document, part of a court filing, argues that a new trial is necessary due to the implied and inferable bias of Juror No. 50. The author contends that if the juror had answered voir dire questions truthfully, it would have provided a valid basis for a challenge for cause. The document refutes the government's legal arguments by citing precedents like United States v. Daugerdas and United States v. Torres, and suggests a hearing is needed to evaluate the juror's actual partiality.
People (6)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
The subject of a legal argument regarding potential bias and untruthful answers during voir dire.
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| Martinez-Salazar |
Mentioned in the case citation 'Martinez-Salazar, 528 U.S. at 316'.
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| Torres |
Mentioned in the case citation 'United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997)'.
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| Daugerdas |
Mentioned in the case citation 'United States v. Daugerdas, 867 F. Supp. 2d 445, 468 (S.D.N.Y. 2012)'.
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| McDonough |
Mentioned in relation to a legal reading urged by the Government and in a case citation 'McDonough, 464 U.S. at 556'.
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| Parse |
Mentioned in the case citation 'United States v. Parse, 789 F.3d 83 (2d Cir. 2015)'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
Referred to as the judicial body being addressed in the filing.
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| United States | government agency |
Party in several cited legal cases, such as 'United States v. Torres'.
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| DOJ-OGR | government agency |
Appears in the footer document identifier 'DOJ-OGR-00009890'.
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Timeline (3 events)
Argument that Juror No. 50's implied and inferable bias requires a new trial.
Voir dire process during which a prospective juror makes statements.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in a case citation as the Southern District of New York court.
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Relationships (1)
Filing Party (implied)
→
adversarial
→
Government
The document argues against the Government's legal position, stating the Government 'attempts to raise the bar for relief' and that its contention is contrary to the proper legal test.
Key Quotes (3)
"A juror is found by the judge to be partial either because the juror admits partiality, or the judge finds actual partiality based upon the juror’s voir dire answers."Source
— United States v. Torres
(Quoted to explain the basis for determining juror partiality.)
DOJ-OGR-00009890.jpg
Quote #1
"The Government urges this Court to adopt a narrow reading of McDonough unsupported by law."Source
— The author of the document
(Describing the government's legal position in the case of United States v. Daugerdas.)
DOJ-OGR-00009890.jpg
Quote #2
"would have provided a valid basis for a challenge for cause."Source
— United States v. Daugerdas
(Quoted to establish the test for whether a truthful response from a juror warrants relief.)
DOJ-OGR-00009890.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,065 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 21 of 32
D. If Juror No. 50 had truthfully answered Questions 25 and 48, the correct responses would have provided a valid basis for a challenge for cause.
It is both unnecessary and premature for this Court to consider whether Juror No. 50 was actually biased.
It’s unnecessary because any bias is sufficient to require a new trial, and here the record shows that Juror No. 50 was both impliedly and inferably biased. Because Juror No. 50 was impliedly and inferably biased, a new trial is required. Martinez-Salazar, 528 U.S. at 316. And it’s premature because the actual bias inquiry depends in part on the statements a prospective juror makes during voir dire. United States v. Torres, 128 F.3d 38, 43 (2d Cir. 1997) (“A juror is found by the judge to be partial either because the juror admits partiality, or the judge finds actual partiality based upon the juror’s voir dire answers.”). Here, Juror No. 50 hasn’t had to answers the questions that would have been posed to him if he had answered Questions 25 and 48 truthfully. Only a hearing—if this Court orders one—will permit the Court and parties to evaluate actual partiality.
The government here attempts to raise the bar for relief, just as it did in United States v. Daugerdas: “The Government urges this Court to adopt a narrow reading of McDonough unsupported by law. But contrary to the Government’s contention, the test is not whether the true facts would compel the Court to remove a juror for cause, but rather whether a truthful response ‘would have provided a valid basis for a challenge for cause.’” United States v. Daugerdas, 867 F. Supp. 2d 445, 468 (S.D.N.Y. 2012) (ordering new trial for two of three defendants based on juror providing false answers during voir dire and concluding that the third defendant waived the new trial argument), vacated and remanded sub nom. United States v. Parse, 789 F.3d 83 (2d Cir. 2015) (reversing district court’s waiver conclusion) (quoting McDonough, 464 U.S. at 556).
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DOJ-OGR-00009890
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