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642 KB
Extraction Summary
3
People
3
Organizations
1
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Court order / legal opinion (page 32 of 40 from case 1:20-cr-00330-ajn)
File Size:
642 KB
Summary
This document is page 32 of a 40-page court order filed on April 1, 2022, in the case of United States v. Ghislaine Maxwell. The text discusses the legal standard for 'implied bias' regarding jurors, specifically rejecting the argument that a juror must be presumed biased simply for having personal experiences similar to the issues at trial. The court cites Second Circuit precedents (Daugerdas, Torres, Brown, Garcia) to support the conclusion that implied bias is a narrow category reserved for extreme situations, such as deliberate lying to get on a jury, rather than merely shared experiences.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referenced as 'The Defendant' and in citations 'Maxwell Br.' and 'Maxwell Post-Hearing Br.'.
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| Alison J. Nathan | Judge |
Implied by case number suffix 'AJN'.
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| Juror (Unnamed) | Juror |
Subject of the legal discussion regarding implied bias and personal experiences similar to issues at trial.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Second Circuit Court of Appeals |
Referenced as the controlling legal authority ('The Second Circuit has made clear...').
|
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| District Court |
Referenced in relation to the Daugerdas opinion.
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| Department of Justice (DOJ) |
Indicated by the footer stamp 'DOJ-OGR'.
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Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Cited in legal precedent (D. Mass. 2011).
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Relationships (1)
The Court is ruling on arguments presented in 'Maxwell Br.' and 'Maxwell Post-Hearing Br.'
Key Quotes (5)
"The Court is unpersuaded."Source
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Quote #1
"First, the Second Circuit has not held that bias must be implied when a juror has a personal experience similar to the issues at trial."Source
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Quote #2
"The Second Circuit has made clear that implied bias is an intentionally narrow category."Source
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Quote #3
"implied bias because of that juror’s “brazen[],” “deliberate,” and “repeated lies” and creation of “a totally fictitious persona in her drive to get on the jury.”"Source
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Quote #4
"“[s]uch cases are unlikely to present the ‘extreme situations’ that call for mandatory"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,241 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page149 of 221
A-349
A-349
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 32 of 40
The Court is unpersuaded. First, the Second Circuit has not held that bias must be
implied when a juror has a personal experience similar to the issues at trial. The Defendant’s
only in-circuit decision is the district court opinion in Daugerdas. See Maxwell Br. at 30–35;
Maxwell Post-Hearing Br. at 5. In passing, the Daugerdas court noted that “[c]ourts imply bias
‘when there are similarities between the personal experiences of the juror and the issues being
litigated.’” 867 F. Supp. 2d at 472 (quoting United States v. Sampson, 820 F. Supp. 2d 151, 164
(D. Mass. 2011)). But the court resolved the motion on other grounds—it did not imply bias
because that juror had similar experiences to those at issue in the trial, but instead (as discussed
above) implied bias because of that juror’s “brazen[],” “deliberate,” and “repeated lies” and
creation of “a totally fictitious persona in her drive to get on the jury.” Id. at 472–74.
implied when a juror has a personal experience similar to the issues at trial. The Defendant’s
only in-circuit decision is the district court opinion in Daugerdas. See Maxwell Br. at 30–35;
Maxwell Post-Hearing Br. at 5. In passing, the Daugerdas court noted that “[c]ourts imply bias
‘when there are similarities between the personal experiences of the juror and the issues being
litigated.’” 867 F. Supp. 2d at 472 (quoting United States v. Sampson, 820 F. Supp. 2d 151, 164
(D. Mass. 2011)). But the court resolved the motion on other grounds—it did not imply bias
because that juror had similar experiences to those at issue in the trial, but instead (as discussed
above) implied bias because of that juror’s “brazen[],” “deliberate,” and “repeated lies” and
creation of “a totally fictitious persona in her drive to get on the jury.” Id. at 472–74.
The Second Circuit has made clear that implied bias is an intentionally narrow category.
The circuit has “consistently refused ‘to create a set of unreasonably constricting presumptions
that jurors be excused for cause due to certain occupational or other special relationships which
might bear directly or indirectly on the circumstances of a given case, where . . . there is no
showing of actual bias or prejudice.’” Torres, 128 F.3d at 46 (quoting United States v. Brown,
644 F.2d 101, 104–05 (2d Cir. 1981)); see also United States v. Garcia, 936 F.2d 648, 652 (2d
Cir. 1991). As noted above, the Torres court held that it was not an abuse of discretion for the
trial court to infer that a juror was biased when she engaged in money structuring activities that
were similar to conduct charged in the case. 128 F.3d at 46–47. But the circuit “decline[d] to
hold as a general matter that, where a juror has engaged in conduct similar to that of the
defendant at trial, the trial judge must presume bias.” Id. at 46 (emphasis added). As the court
explained, “[s]uch cases are unlikely to present the ‘extreme situations’ that call for mandatory
The circuit has “consistently refused ‘to create a set of unreasonably constricting presumptions
that jurors be excused for cause due to certain occupational or other special relationships which
might bear directly or indirectly on the circumstances of a given case, where . . . there is no
showing of actual bias or prejudice.’” Torres, 128 F.3d at 46 (quoting United States v. Brown,
644 F.2d 101, 104–05 (2d Cir. 1981)); see also United States v. Garcia, 936 F.2d 648, 652 (2d
Cir. 1991). As noted above, the Torres court held that it was not an abuse of discretion for the
trial court to infer that a juror was biased when she engaged in money structuring activities that
were similar to conduct charged in the case. 128 F.3d at 46–47. But the circuit “decline[d] to
hold as a general matter that, where a juror has engaged in conduct similar to that of the
defendant at trial, the trial judge must presume bias.” Id. at 46 (emphasis added). As the court
explained, “[s]uch cases are unlikely to present the ‘extreme situations’ that call for mandatory
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