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Extraction Summary
3
People
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Organizations
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Locations
3
Events
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Relationships
4
Quotes
Document Information
Type:
Court order / legal ruling (page 5 of document 620)
File Size:
705 KB
Summary
This document is page 5 of a court filing (Case 1:20-cr-00330-PAE) dated February 25, 2022. The Court denies the Defendant's (Maxwell) motion for an immediate new trial based on the current record but rules that an evidentiary hearing must be held to investigate Juror 50's alleged nondisclosure of sexual abuse history during jury selection. The text cites the 'McDonough standard' and legal precedents requiring hearings when juror impartiality is in doubt.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Referred to in the text (Ghislaine Maxwell, implied by 'Maxwell Br.'); requesting a new trial based on juror misconduct.
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| Juror 50 | Juror |
Juror accused of nondisclosure regarding sexual abuse history and making unsworn statements to media outlets.
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| The Court | Judge/Judicial Authority |
The entity issuing the decision to deny the motion for a new trial on the current record and ordering an evidentiary ...
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Second Circuit |
Cited for legal precedent regarding evidentiary hearings.
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| D.C. Cir. |
Cited in legal precedent (United States v. Boney).
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| DOJ |
Indicated in the footer stamp 'DOJ-OGR-00009546'.
|
Relationships (1)
Defendant claims Juror 50 lied during selection and misconduct occurred during deliberation.
Key Quotes (4)
"The Court therefore denies the Defendant’s motion to grant a new trial on the current record."Source
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Quote #1
"Juror 50 deliberately lied in failing to disclose that he was the victim of sexual abuse."Source
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Quote #2
"if any significant doubt as to a juror’s impartiality remains in the wake of objective evidence of false voir dire responses, an evidentiary hearing generally should be held."Source
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Quote #3
"For the reasons outlined below, the Court determines that a hearing must be held regarding Juror 50’s alleged nondisclosure during the jury selection process."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,063 characters)
Case 1:20-cr-00330-PAE Document 620 Filed 02/25/22 Page 5 of 21
The Defendant urges this Court to resolve the motion on the papers, without the need for
a hearing. Maxwell Br. at 28. But resolving the motion now would require the Court to accept
as true Juror 50’s unsworn statements made to media outlets. Moreover, in arguing for a new
trial based on the current record, the Defendant relies extensively on statements prohibited from
consideration by Rule 606. E.g., Maxwell Br. at 12–14 (describing Juror 50’s statements in
deliberation and other jurors’ reactions). The Defendant also urges the Court to reach factual
conclusions that are unavailable on the current record; for example, that Juror 50 deliberately
lied in failing to disclose that he was the victim of sexual abuse. See Maxwell Br. at 39–43.
Finally, the Defendant cites no authority—nor is the Court aware of any—in which a court
granted a new trial under the McDonough standard without first conducting an evidentiary
hearing. As the Second Circuit has instructed, “if any significant doubt as to a juror’s
impartiality remains in the wake of objective evidence of false voir dire responses, an
evidentiary hearing generally should be held.” United States v. Stewart, 433 F.3d 273, 306 (2d
Cir. 2006) (citing United States v. Boney, 977 F.2d 624, 634 (D.C. Cir. 1992)). The Court
therefore denies the Defendant’s motion to grant a new trial on the current record.
a hearing. Maxwell Br. at 28. But resolving the motion now would require the Court to accept
as true Juror 50’s unsworn statements made to media outlets. Moreover, in arguing for a new
trial based on the current record, the Defendant relies extensively on statements prohibited from
consideration by Rule 606. E.g., Maxwell Br. at 12–14 (describing Juror 50’s statements in
deliberation and other jurors’ reactions). The Defendant also urges the Court to reach factual
conclusions that are unavailable on the current record; for example, that Juror 50 deliberately
lied in failing to disclose that he was the victim of sexual abuse. See Maxwell Br. at 39–43.
Finally, the Defendant cites no authority—nor is the Court aware of any—in which a court
granted a new trial under the McDonough standard without first conducting an evidentiary
hearing. As the Second Circuit has instructed, “if any significant doubt as to a juror’s
impartiality remains in the wake of objective evidence of false voir dire responses, an
evidentiary hearing generally should be held.” United States v. Stewart, 433 F.3d 273, 306 (2d
Cir. 2006) (citing United States v. Boney, 977 F.2d 624, 634 (D.C. Cir. 1992)). The Court
therefore denies the Defendant’s motion to grant a new trial on the current record.
III. Evidentiary hearing
For the reasons outlined below, the Court determines that a hearing must be held
regarding Juror 50’s alleged nondisclosure during the jury selection process.
regarding Juror 50’s alleged nondisclosure during the jury selection process.
A. Threshold for an evidentiary hearing
Because of the importance of finality of judgments, the threshold for conducting a post-
verdict inquiry is high. A post-verdict inquiry into juror misconduct is conducted only “when
there is clear, strong, substantial and incontrovertible evidence that a specific, nonspeculative
impropriety has occurred which could have prejudiced the trial of a defendant.” United States v.
verdict inquiry is high. A post-verdict inquiry into juror misconduct is conducted only “when
there is clear, strong, substantial and incontrovertible evidence that a specific, nonspeculative
impropriety has occurred which could have prejudiced the trial of a defendant.” United States v.
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DOJ-OGR-00009546
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