DOJ-OGR-00010353.jpg
771 KB
Extraction Summary
8
People
6
Organizations
0
Locations
2
Events
1
Relationships
7
Quotes
Document Information
Type:
Legal document
File Size:
771 KB
Summary
This legal document is a court opinion from Case 1:20-cr-00330-PAE, filed on April 1, 2022. The court analyzes and rejects the Defendant's (Maxwell's) argument that Juror 50 was biased due to dishonest answers on a jury questionnaire. The court distinguishes this case from precedents involving deliberate deception, crediting Juror 50's explanation that his nondisclosure was an 'inadvertent mistake' resulting from personal distractions and 'skimming' the form.
People (8)
| Name | Role | Context |
|---|---|---|
| Gonzales | Party in a legal case |
Mentioned in the case citation Gonzales v. Thomas.
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| Thomas | Party in a legal case |
Mentioned in the case citation Gonzales v. Thomas.
|
| Buckner | Party in a legal case |
Mentioned in the case citation Buckner v. Davis.
|
| Davis | Party in a legal case |
Mentioned in the case citation Buckner v. Davis.
|
| Juror 50 | Juror |
The subject of the court's analysis regarding potential bias and nondisclosure on a questionnaire.
|
| Maxwell | Defendant |
The Defendant in the case, who is arguing that Juror 50 was biased. Referred to in 'Maxwell Br.' and 'Maxwell Post-He...
|
| Daugerdas | Party in a legal case |
Mentioned in the case citation United States v. Daugerdas, which the Defendant relies on.
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| Parse | Party in a legal case |
Mentioned in the case citation United States v. Parse.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| 10th Cir. | government agency |
Referenced in the citation for Gonzales v. Thomas, 99 F.3d 978, 989–90 (10th Cir. 1996).
|
| 5th Cir. | government agency |
Referenced in the citation for Buckner v. Davis, 945 F.3d 906, 914–15 (5th Cir. 2019).
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| United States | government agency |
Party in the cases United States v. Daugerdas and United States v. Parse.
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| S.D.N.Y. | government agency |
Referenced in the citation for United States v. Daugerdas, 867 F. Supp. 2d 445, 473 (S.D.N.Y. 2012).
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| 2d Cir. | government agency |
Referenced in the citation for United States v. Parse, 789 F.3d 83 (2d Cir. 2015).
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| DOJ | government agency |
Appears in the footer as part of the Bates number 'DOJ-OGR-00010353'.
|
Key Quotes (7)
"To hold that no rape victim could ever be an impartial juror in a rape trial would, we think, insult not only all rape victims but also our entire jury system."Source
— 10th Cir. Court
(Quoted from Gonzales v. Thomas to support the principle that a victim of a similar crime is not automatically biased.)
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Quote #1
"dishonest answers"Source
— The Defendant (Maxwell)
(The Defendant's characterization of Juror 50's responses, used as a basis for arguing implied bias.)
DOJ-OGR-00010353.jpg
Quote #2
"created a totally fictitious persona in her drive to get on the jury."Source
— S.D.N.Y. Court
(Description of the juror's actions in United States v. Daugerdas, a case contrasted with the current one.)
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Quote #3
"deliberate lies engineered to create a fictitious, ‘marketable’ juror"Source
— S.D.N.Y. Court
(The court's reasoning in United States v. Daugerdas for granting a new trial.)
DOJ-OGR-00010353.jpg
Quote #4
"extraordinary relief"Source
— S.D.N.Y. Court
(The type of relief warranted in the Daugerdas case due to the juror's deliberate lies.)
DOJ-OGR-00010353.jpg
Quote #5
"inadvertent mistake"Source
— Juror 50
(Juror 50's explanation for his nondisclosure on the questionnaire, which the Court credited.)
DOJ-OGR-00010353.jpg
Quote #6
"skimming"Source
— Juror 50
(How Juror 50 described his reading of the questionnaire, offered as a reason for missing a personal question.)
DOJ-OGR-00010353.jpg
Quote #7
Full Extracted Text
Complete text extracted from the document (2,444 characters)
Case 1:20-cr-00330-PAE Document 653 Filed 04/01/22 Page 30 of 40
impartial juror in such a trial. That is not the law, nor should it be. See Gonzales v. Thomas, 99 F.3d 978, 989–90 (10th Cir. 1996) (“To hold that no rape victim could ever be an impartial juror in a rape trial would, we think, insult not only all rape victims but also our entire jury system.”); Buckner v. Davis, 945 F.3d 906, 914–15 (5th Cir. 2019) (affirming conclusion that juror who failed to disclose childhood abuse was not impliedly biased in conviction for sexual assault of a child). Thus, the Court finds no basis to infer that Juror 50 is biased.
The Defendant’s arguments to the contrary do not disturb the Court’s conclusion that Juror 50 was neither impliedly nor inferably biased. First, the Defendant argues that Juror 50 was impliedly biased because of multiple “dishonest answers.” Maxwell Br. at 36; Maxwell Post-Hearing Br. at 11.⁸ But this is not a case involving a juror’s extreme deceit due to a desire to be selected. By contrast, in United States v. Daugerdas, on which the Defendant extensively relies, a juror “created a totally fictitious persona in her drive to get on the jury.” 867 F. Supp. 2d 445, 473 (S.D.N.Y. 2012), vacated and remanded on other grounds, United States v. Parse, 789 F.3d 83 (2d Cir. 2015). The court granted the defendant’s motion for a new trial, emphasizing the “deliberate lies engineered to create a fictitious, ‘marketable’ juror” warranted “extraordinary relief.” Id. at 468. Such is not the case here. The Court credits Juror 50’s explanation that his nondisclosure was an “inadvertent mistake,” not intentional deception. Hearing Tr. at 14–15. Juror 50 explained how the circumstances surrounding his completion of the questionnaire—including his recent romantic breakup, that he had no expectation of being selected, the technical issues and ensuing long wait to begin the questionnaire, and the generally distracting environment—resulted in his “skimming” the questionnaire and missing the personal
The Defendant’s arguments to the contrary do not disturb the Court’s conclusion that Juror 50 was neither impliedly nor inferably biased. First, the Defendant argues that Juror 50 was impliedly biased because of multiple “dishonest answers.” Maxwell Br. at 36; Maxwell Post-Hearing Br. at 11.⁸ But this is not a case involving a juror’s extreme deceit due to a desire to be selected. By contrast, in United States v. Daugerdas, on which the Defendant extensively relies, a juror “created a totally fictitious persona in her drive to get on the jury.” 867 F. Supp. 2d 445, 473 (S.D.N.Y. 2012), vacated and remanded on other grounds, United States v. Parse, 789 F.3d 83 (2d Cir. 2015). The court granted the defendant’s motion for a new trial, emphasizing the “deliberate lies engineered to create a fictitious, ‘marketable’ juror” warranted “extraordinary relief.” Id. at 468. Such is not the case here. The Court credits Juror 50’s explanation that his nondisclosure was an “inadvertent mistake,” not intentional deception. Hearing Tr. at 14–15. Juror 50 explained how the circumstances surrounding his completion of the questionnaire—including his recent romantic breakup, that he had no expectation of being selected, the technical issues and ensuing long wait to begin the questionnaire, and the generally distracting environment—resulted in his “skimming” the questionnaire and missing the personal
⁸ The Defendant argued that these repeated lies included Juror 50’s use of social media in her pre-hearing briefing. Maxwell Br. at 36. For the reasons stated in this Court’s February 25 Opinion, that Juror 50 used social media accounts after the completion of trial does not establish that he lied about having been inactive on social media before trial. Feb. 25, 2020 Op. & Order, at 9–10.
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DOJ-OGR-00010353
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