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Extraction Summary
2
People
4
Organizations
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Locations
2
Events
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Relationships
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Quotes
Document Information
Type:
Court filing / legal brief
File Size:
680 KB
Summary
This document is page 32 of a legal filing (Document 613) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). It discusses legal precedents regarding juror misconduct, specifically citing the Supreme Court's decision in McDonough Power Equipment, Inc. v. Greenwood (referenced via 'Id.' and the mention of 'Juror Payton'). The text outlines the legal standard required to obtain a new trial when a juror fails to answer voir dire questions honestly.
People (2)
| Name | Role | Context |
|---|---|---|
| Juror Payton | Juror in cited precedent case |
Subject of a legal precedent regarding juror nondisclosure; her son was injured in an explosion.
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| Juror Payton's son | Family member of juror |
Injured in an explosion of a fire truck.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| District Court |
Denied original motion for new trial in the cited case.
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| Court of Appeals |
Reversed the district court in the cited case.
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| Supreme Court |
Reversed the Court of Appeals and established the legal standard for new trials based on juror dishonesty.
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| DOJ |
Indicated by Bates stamp DOJ-OGR.
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Timeline (2 events)
Unknown (Historical Precedent)
Relationships (1)
Text mentions 'Juror Payton’s son'
Key Quotes (3)
"to obtain a new trial in such a situation, a party 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
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Quote #1
"“[v]oir dire examination serves to protect [the fair trial] right by exposing possible biases, both known and unknown, on the part of potential jurors”"Source
DOJ-OGR-00009033.jpg
Quote #2
"“Good faith,” said the court, was “irrelevant to the inquiry.”"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,847 characters)
Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 32 of 66
that Juror Payton’s son had been injured in an explosion of a fire truck. Id. at 551. The
district court denied a motion for a new trial without holding a hearing. Id.
district court denied a motion for a new trial without holding a hearing. Id.
The court of appeals reversed, ordering a new trial instead of remanding for a
hearing. Id. at 551-52. The court of appeals held that if “an average prospective juror
would have disclosed the information, and that information would have been significant
and cogent evidence of the juror’s probable bias, a new trial is required to rectify the
failure to disclose it.” Id. at 552. “Good faith,” said the court, was “irrelevant to the
inquiry.” Id.
hearing. Id. at 551-52. The court of appeals held that if “an average prospective juror
would have disclosed the information, and that information would have been significant
and cogent evidence of the juror’s probable bias, a new trial is required to rectify the
failure to disclose it.” Id. at 552. “Good faith,” said the court, was “irrelevant to the
inquiry.” Id.
The Supreme Court reversed the court of appeals, concluding that it employed the
wrong standard and erred in reaching the merits instead of remanding the case to the
district court for an evidentiary hearing. Id. at 556. As for the correct legal standard, the
Court said that
wrong standard and erred in reaching the merits instead of remanding the case to the
district court for an evidentiary hearing. Id. at 556. As for the correct legal standard, the
Court said that
to obtain a new trial in such a situation, a party 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.
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.
Id. The Court remanded to the court of appeals to consider any outstanding issues and,
assuming the judgment wasn’t reversed for other reasons, to remand to the district court
for an evidentiary hearing applying the new legal standard. Id.
assuming the judgment wasn’t reversed for other reasons, to remand to the district court
for an evidentiary hearing applying the new legal standard. Id.
The court emphasized that “[v]oir dire examination serves to protect [the fair trial]
right by exposing possible biases, both known and unknown, on the part of potential
jurors” and that the “necessity of truthful answers by prospective jurors if [voir dire] is to
serve its purpose is obvious.” Id. at 554. The Court did not expressly disavow the court of
right by exposing possible biases, both known and unknown, on the part of potential
jurors” and that the “necessity of truthful answers by prospective jurors if [voir dire] is to
serve its purpose is obvious.” Id. at 554. The Court did not expressly disavow the court of
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