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Extraction Summary
4
People
4
Organizations
0
Locations
2
Events
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Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
600 KB
Summary
This legal document, page 18 of a court filing dated December 2, 2024, discusses the District Court's denial of a Rule 33 motion for a new trial. The motion was based on an allegedly erroneous answer given by 'Juror 50' during voir dire. The document explains that the court applied the standard from 'McDonough v. Greenwood', finding the juror's testimony credible and his response not deliberately incorrect, and also noting that the defendant, Maxwell, had not challenged other jurors with similar backgrounds.
People (4)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
Mentioned as the subject of a motion due to alleged erroneous responses during voir dire. The District Court found th...
|
| Maxwell | Party to the case |
Mentioned as the party who did not challenge the inclusion of other jurors with similar past experiences.
|
| Gambino | Party in a cited case |
Mentioned in the case citation 'United States v. Gambino'.
|
| Greenwood | Party in a cited case |
Mentioned in the case citation 'McDonough Power Equipment, Inc. v. Greenwood'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| McDonough Power Equipment, Inc. | company |
A party in the cited case 'McDonough Power Equipment, Inc. v. Greenwood', which established the legal standard being ...
|
| District Court | court |
The court that applied the McDonough standard and made findings regarding Juror 50's testimony and responses.
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| Supreme Court | court |
Cited for its opinion in the McDonough case regarding the standard for invalidating a trial based on a juror's mistak...
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| United States | government agency |
A party in the cited case 'United States v. Gambino'.
|
Timeline (2 events)
Key Quotes (4)
"must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause."Source
— McDonough standard
(Describing the two-part test a party must meet when seeking a new trial based on a juror's response during voir dire.)
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Quote #1
"not deliberately incorrect"Source
— District Court
(The District Court's determination regarding Juror 50's erroneous responses during voir dire.)
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Quote #2
"he would not have been struck for cause if he had provided accurate responses to the questionnaire."Source
— District Court
(The District Court's finding regarding the potential outcome had Juror 50 answered correctly.)
DOJ-OGR-00021895.jpg
Quote #3
"[t]o invalidate the result of a [ ] trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give."Source
— Supreme Court
(A quote from the McDonough case explaining the high bar for overturning a trial result due to a juror's honest mistake.)
DOJ-OGR-00021895.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,541 characters)
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page18 of 26
broad discretion to decide Rule 33 motions based upon its evaluation of the proof produced” and is shown deference on appeal.30
A Rule 33 motion based on a juror’s alleged erroneous response during voir dire is governed by McDonough Power Equipment, Inc. v. Greenwood.31 Under McDonough, a party seeking a new trial “must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.”32
The District Court applied the McDonough standard, found Juror 50’s testimony credible, and determined that Juror 50’s erroneous responses during voir dire were “not deliberately incorrect” and that “he would not have been struck for cause if he had provided accurate responses to the questionnaire.”33 In fact, as the District Court noted, Maxwell did not challenge the inclusion of other jurors who disclosed past experience with sexual abuse, assault, or harassment. This is
30 United States v. Gambino, 59 F.3d 353, 364 (2d Cir. 1995) (citation and internal quotation marks omitted).
31 464 U.S. 548 (1984).
32 Id. at 556.
33 A-340 (emphasis added). The Supreme Court reminds us that “[t]o invalidate the result of a [ ] trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.” McDonough, 464 U.S. at 555.
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DOJ-OGR-00021895
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