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Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
715 KB
Summary
This legal document, filed on March 11, 2022, presents an argument on behalf of Ms. Maxwell that Juror No. 50 intentionally provided false answers to questions during the jury selection process (voir dire). The document asserts that Ms. Maxwell has met the burden of proof for this claim, citing legal precedents and suggesting that video evidence of the juror being confronted supports the allegation of intentional falsehood. The ultimate goal is to argue for the juror's implied or actual bias.
People (5)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
The subject of the legal argument, accused of providing intentionally false answers during voir dire.
|
| Ms. Maxwell | Party in a legal case |
The individual arguing that Juror No. 50 intentionally provided false answers and was biased.
|
| Haynes |
Party in the cited case United States v. Haynes.
|
|
| Rosales-Lopez |
Party in the cited case Rosales-Lopez v. United States.
|
|
| Stewart |
Party in a cited case, Stewart, 433 F.3d at 303.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in the cited cases United States v. Haynes and Rosales-Lopez v. United States.
|
| Court | government agency |
The judicial body being addressed in the document, which is being asked to rule on the issue of Juror No. 50's allege...
|
Timeline (2 events)
Argument that Juror No. 50 provided intentionally false answers to Questions 25 and 48 during voir dire.
A potential future evidentiary hearing where Juror No. 50 would be compelled to give truthful answers.
Relationships (1)
Ms. Maxwell is accusing Juror No. 50 of intentionally misleading the court with false answers during the jury selection process.
Key Quotes (3)
"actual bias is “based upon express proof, e.g., by a voir dire admission by the prospective juror of a state of mind prejudicial to a party’s interest”"Source
— United States v. Haynes, 398 F.2d 980, 984 (2d Cir. 1968)
(Cited as legal precedent for defining actual bias.)
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Quote #1
"Without an adequate voir dire the trial judge’s responsibility to remove prospective jurors who will not be able impartially to follow the court’s instructions and evaluate the evidence cannot be fulfilled."Source
— Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981) (plurality opinion)
(Cited as legal precedent regarding the importance of voir dire.)
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Quote #2
"first, that the juror’s voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause."Source
— Stewart, 433 F.3d at 303
(Cited as the two-part test Ms. Maxwell needs to prove regarding Juror No. 50's answers.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,917 characters)
Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 46 of 66
based upon the juror’s voir dire answers.” Id. (citing United States v. Haynes, 398 F.2d
980, 984 (2d Cir. 1968) (actual bias is “based upon express proof, e.g., by a voir dire
admission by the prospective juror of a state of mind prejudicial to a party’s interest”);
Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981) (plurality opinion) (“Without
an adequate voir dire the trial judge’s responsibility to remove prospective jurors who
will not be able impartially to follow the court’s instructions and evaluate the evidence
cannot be fulfilled.”)).
980, 984 (2d Cir. 1968) (actual bias is “based upon express proof, e.g., by a voir dire
admission by the prospective juror of a state of mind prejudicial to a party’s interest”);
Rosales-Lopez v. United States, 451 U.S. 182, 188 (1981) (plurality opinion) (“Without
an adequate voir dire the trial judge’s responsibility to remove prospective jurors who
will not be able impartially to follow the court’s instructions and evaluate the evidence
cannot be fulfilled.”)).
This Court need not decide whether Juror No. 50 was actually biased, since this
Court can and should imply and infer bias. Assuming this Court holds an evidentiary
hearing at which Juror No. 50 is compelled to give truthful answers to the questions he
would have been asked if he had not falsely responded to the questionnaire, Ms. Maxwell
reserves the right to argue that Juror No. 50 was actually biased.
Court can and should imply and infer bias. Assuming this Court holds an evidentiary
hearing at which Juror No. 50 is compelled to give truthful answers to the questions he
would have been asked if he had not falsely responded to the questionnaire, Ms. Maxwell
reserves the right to argue that Juror No. 50 was actually biased.
C. Juror No. 50’s answers to Questions 25 and 48 were intentionally false.
Ms. Maxwell does not need to prove that Juror No. 50’s voir dire answers were
intentionally false. As explained above, she need only prove “first, that the juror’s voir
dire response was false and second, that the correct response would have provided a valid
basis for a challenge for cause.” Stewart, 433 F.3d at 303. Nevertheless, assuming this
Court concludes that Ms. Maxwell must prove Juror No. 50 intentionally misled the
Court in falsely answering Questions 25 and 48, Ms. Maxwell has easily met that burden.
intentionally false. As explained above, she need only prove “first, that the juror’s voir
dire response was false and second, that the correct response would have provided a valid
basis for a challenge for cause.” Stewart, 433 F.3d at 303. Nevertheless, assuming this
Court concludes that Ms. Maxwell must prove Juror No. 50 intentionally misled the
Court in falsely answering Questions 25 and 48, Ms. Maxwell has easily met that burden.
There are at least six reasons to believe Juror No. 50 acted intentionally. First, this
Court need only watch the video of Juror No. 50 being confronted with his false answers
to appreciate that he acted intentionally. Juror No. 50’s face immediately flushed and
Court need only watch the video of Juror No. 50 being confronted with his false answers
to appreciate that he acted intentionally. Juror No. 50’s face immediately flushed and
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