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767 KB
Extraction Summary
4
People
2
Organizations
5
Locations
4
Events
0
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
767 KB
Summary
This document, a page from a legal filing, discusses the legal precedent for dividing a judicial district for the purpose of jury selection. It centers on the Second Circuit's decision in United States v. Bahna, where a defendant's second trial was moved to a different courthouse that drew jurors from a smaller, less diverse geographic pool than the entire district. The Second Circuit upheld this practice, ruling that the fairness of a jury pool should be evaluated based on the specific division from which it is drawn, not the district as a whole, especially when the division is based on administrative feasibility.
People (4)
| Name | Role | Context |
|---|---|---|
| Gottfried | Party in a legal case |
Mentioned in the case citation United States v. Gottfried, 165 F.2d 360, 364 (2d Cir. 1948).
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| Allen | Party in a legal case |
Mentioned in the case citation See Allen, 2021 WL 431458, at *1.
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| Bahna | Defendant |
Defendant in the case United States v. Bahna, 68 F.3d 19 (2d Cir. 1995), whose trials are the central example discussed.
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| Soares | Party in a legal case |
Mentioned in the footnote case citation Soares v. United States, 66 F. Supp. 2d 391, 397 (E.D.N.Y. 1999).
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Second Circuit | government agency |
A U.S. Court of Appeals whose decision in United States v. Bahna is discussed.
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| Eastern District of New York | government agency |
The U.S. District Court where the Bahna trials took place. Mentioned in relation to its Jury Plan and courthouses.
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Timeline (4 events)
1995
The Second Circuit rejected the defendant's reasoning in the Bahna case and upheld the conviction.
Locations (5)
| Location | Context |
|---|---|
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The geographic and jurisdictional area where the legal events took place.
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The venue for the first trial of the defendant in the Bahna case, which drew jurors from all counties in the Eastern ...
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The venue for the second trial of the defendant in the Bahna case, which drew jurors only from Nassau and Suffolk cou...
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One of the two counties from which the Uniondale courthouse drew its jurors.
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One of the two counties from which the Uniondale courthouse drew its jurors.
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Key Quotes (3)
"an impartial trial, of economy and of lessening the burden of attendance."Source
— United States v. Gottfried
(Cited as the interests for which a District's Jury Plan can divide territorially.)
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Quote #1
"Where a jury venire is drawn from a properly designated division, we look to that division to see whether there has"Source
— Second Circuit
(Part of the holding from the United States v. Bahna case, explaining the standard for reviewing jury selection in a specific judicial division.)
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Quote #2
"was to accommodate trial congestion in the court’s calendar during a period of judicial emergency in the Eastern District."Source
— trial court (cited in Soares v. United States)
(The stated reason for transferring the Bahna trial to the Uniondale courthouse, as mentioned in a footnote.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,100 characters)
Case 20-17-00335-APAC Document 859 Filed 03/26/21 Page 10 of 20
undivided, the District’s Jury Plan can divide territorially in the interests of “an impartial trial, of economy and of lessening the burden of attendance.” United States v. Gottfried, 165 F.2d 360, 364 (2d Cir. 1948); see Jury Plan. Accordingly, the rationale justifying this territorial division is based on administrative feasibility. See Allen, 2021 WL 431458, at *1.
With this background in mind, the legal issue at hand becomes straightforward. The Second Circuit’s decision in United States v. Bahna, 68 F.3d 19 (2d Cir. 1995), frames the inquiry and supplies its answer. In Bahna, a defendant was indicted, tried, and convicted of various narcotics crimes in the Eastern District of New York’s Brooklyn courthouse. Id. at 20. But following his initial trial, the defendant was granted a new trial. Id. Saliently, the defendant’s second trial occurred before a different judge and in a different venue—the Eastern District’s Uniondale courthouse.5 Id.
Of concern here, the defendant raised a fair cross-section challenge following his second conviction. Id. at 23–24. Under the Eastern District’s jury plan, the Brooklyn courthouse drew jurors from all of the counties within the Eastern District, while the Uniondale courthouse only drew from Nassau and Suffolk counties. See id. at 24. Accordingly, the defendant argued that the Uniondale courthouse’s jury wheel underrepresented African American and Hispanic American jurors in comparison to their demographics in the relevant community—which he alleged to be all of the counties making up the Eastern District. Id.
The Second Circuit, however, rejected that reasoning and held that, “Where a jury venire is drawn from a properly designated division, we look to that division to see whether there has
5 The trial court stated that the reason for the transfer “was to accommodate trial congestion in the court’s calendar during a period of judicial emergency in the Eastern District.” Soares v. United States, 66 F. Supp. 2d 391, 397 (E.D.N.Y. 1999).
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