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Extraction Summary
5
People
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Organizations
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Locations
1
Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
644 KB
Summary
This legal document is a court's analysis concluding that Juror 50 is neither impliedly nor inferably biased against the Defendant. The court reasons that the juror's personal experience of sexual abuse is insufficient to infer partiality and that, based on the voir dire of other jurors, it is unlikely the Defendant would have successfully challenged the juror for cause.
People (5)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
The subject of the court's analysis regarding potential implied or inferable bias against the Defendant.
|
| Defendant | Defendant |
The party in the case who Juror 50 was potentially biased against. The Defendant requested follow-up questions during...
|
| Torres | Case Party |
Mentioned in the citation for the case *Torres*, which dealt with juror bias.
|
| McCoy | Case Party |
Mentioned in the citation for the case *McCoy*.
|
| Nix | Case Party |
Mentioned in the citation for the case *Nix*.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Second Circuit | government agency |
A court that held a trial court did not abuse its discretion in the Torres case regarding juror bias.
|
| The Court | government agency |
The judicial body authoring this document and concluding that Juror 50 is not biased.
|
Full Extracted Text
Complete text extracted from the document (2,211 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page144 of 221
A-344
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 27 of 40
A-344
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 27 of 40
considering whether some marginal types of disclosed facts are enough to show inferable bias—
ask about a juror’s impartiality and might be persuaded by the force of the juror’s assurance.” Id.
at 47 n.12. For example, in Torres, the Second Circuit held that the trial court did not abuse its
discretion when it concluded during voir dire that a juror was inferably biased because she had
engaged in money-structuring activities that were highly similar to the conduct charged in the
case. But the Second Circuit made clear that the district court would not have erred if it had kept
the juror. Id. at 46–48.
The Court concludes that Juror 50 is neither impliedly nor inferably biased. First, none
of the “extreme situations” in which the Court must conclusively presume bias as a matter of law
apply here. McCoy, 995 F.3d at 48. Juror 50 was not a victim of the charged crime itself, nor is
he related to any of the attorneys, witnesses, victims, or other case participants. See Nix, 275 F.
Supp. 3d at 451. Thus, the Court would not have granted a hypothetical challenge for cause
based on implied bias even if Juror 50 had provided correct answers to the questionnaire.
Second, Juror 50’s personal experience of sexual abuse does not evidence partiality
sufficient to infer that Juror 50 was biased against the Defendant. The Court need not imagine a
wholly hypothetical universe for this conclusion. That is because the voir dire provides highly
relevant indications of how the parties and Court would have reacted had Juror 50 provided
accurate answers during jury selection. A review of the voir dire of jurors who responded “yes
(self)” to Question 48 reveals that it is unlikely that the Defendant would have challenged Juror
50 for cause. It also reveals that the Court would not have granted a for-cause challenge had one
been raised. See McCoy, 995 F.3d at 49.
Eight prospective jurors who answered “yes (self)” to Question 48 proceeded to voir dire.
The Court asked every follow-up question requested by the Defendant with regard to a juror’s
ask about a juror’s impartiality and might be persuaded by the force of the juror’s assurance.” Id.
at 47 n.12. For example, in Torres, the Second Circuit held that the trial court did not abuse its
discretion when it concluded during voir dire that a juror was inferably biased because she had
engaged in money-structuring activities that were highly similar to the conduct charged in the
case. But the Second Circuit made clear that the district court would not have erred if it had kept
the juror. Id. at 46–48.
The Court concludes that Juror 50 is neither impliedly nor inferably biased. First, none
of the “extreme situations” in which the Court must conclusively presume bias as a matter of law
apply here. McCoy, 995 F.3d at 48. Juror 50 was not a victim of the charged crime itself, nor is
he related to any of the attorneys, witnesses, victims, or other case participants. See Nix, 275 F.
Supp. 3d at 451. Thus, the Court would not have granted a hypothetical challenge for cause
based on implied bias even if Juror 50 had provided correct answers to the questionnaire.
Second, Juror 50’s personal experience of sexual abuse does not evidence partiality
sufficient to infer that Juror 50 was biased against the Defendant. The Court need not imagine a
wholly hypothetical universe for this conclusion. That is because the voir dire provides highly
relevant indications of how the parties and Court would have reacted had Juror 50 provided
accurate answers during jury selection. A review of the voir dire of jurors who responded “yes
(self)” to Question 48 reveals that it is unlikely that the Defendant would have challenged Juror
50 for cause. It also reveals that the Court would not have granted a for-cause challenge had one
been raised. See McCoy, 995 F.3d at 49.
Eight prospective jurors who answered “yes (self)” to Question 48 proceeded to voir dire.
The Court asked every follow-up question requested by the Defendant with regard to a juror’s
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DOJ-OGR-00020970
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