DOJ-OGR-00009136.jpg
745 KB
Extraction Summary
8
People
6
Organizations
1
Locations
1
Events
0
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
745 KB
Summary
This legal document, part of a court filing, argues that there is no basis to find that 'Juror 50' committed a 'deliberate falsehood' during the jury selection process (voir dire). It cites several legal precedents, primarily from the Second Circuit, to establish that juror misconduct requires proving intentional deceit, not just an honest mistake or failure to answer. The document concludes that the current record does not meet this high threshold to prove dishonesty by Juror 50.
People (8)
| Name | Role | Context |
|---|---|---|
| Shaoul |
Cited as a legal precedent (Shaoul, 41 F.3d at 815) establishing the standard for juror misconduct.
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| Nix |
Cited as a legal precedent (Nix, 275 F. Supp. 3d at 437).
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| Sattar |
Cited as a legal precedent (Sattar, 395 F. Supp. 2d at 72).
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| Ruggiero |
Cited as a legal precedent in the case United States v. Ruggiero.
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| Perez |
Cited as a legal precedent in the case Perez v. Manhattan Jeep Eagle.
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| Juror 50 | Juror |
The subject of the legal argument, accused of potential dishonesty during voir dire.
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| Fitzgerald |
Cited in a footnote as a legal precedent in the case Fitzgerald v. Greene.
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| Greene |
Cited in a footnote as a legal precedent in the case Fitzgerald v. Greene.
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| Second Circuit | court |
Mentioned as the circuit court whose legal standard for juror misconduct is being applied.
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| United States | government |
Party in the case United States v. Ruggiero.
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| Manhattan Jeep Eagle | company |
Party in the case Perez v. Manhattan Jeep Eagle.
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| Government | government agency |
Mentioned in a footnote as assuming Juror 50's public statements were truthful for the purpose of the brief.
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| 4th Cir. | court |
Mentioned in a footnote citation (4th Cir. 1998).
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| DOJ | government agency |
Appears in the footer as part of a document identifier (DOJ-OGR-00009136).
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Locations (1)
| Location | Context |
|---|---|
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Southern District of New York, mentioned in case citations for Ruggiero and Perez cases.
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Key Quotes (3)
"The failure to answer honestly must be deliberate; a ‘juror’s good faith failure to respond, though mistaken, [does] not satisfy even the first prong of the test.’"Source
— Sattar (quoting Shaoul)
(Quoted from the Sattar case, which itself quotes the Shaoul case, to define the high bar for proving juror misconduct.)
DOJ-OGR-00009136.jpg
Quote #1
"it is not clear that [the juror’s] failure to respond to the Court’s question was a deliberate attempt at dishonesty, as she only failed to answer the court’s question."Source
— United States v. Ruggiero case ruling
(Cited as an example of a court rejecting a claim of juror misconduct where intent was not clear.)
DOJ-OGR-00009136.jpg
Quote #2
"[T]he first prong of the test requires a determination of whether juror number one deliberately lied to the Court during voir dire, or whether his answer was the result of a good faith misunderstanding of the question."Source
— Perez v. Manhattan Jeep Eagle case ruling
(Cited to emphasize the requirement of determining if a falsehood was deliberate or a misunderstanding.)
DOJ-OGR-00009136.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,261 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 17 of 49
Shaoul. Thus, in the Second Circuit,⁹ it is a “threshold requirement” to establish that a juror intentionally lied or consciously deceived the court. See Shaoul, 41 F.3d at 815; Nix, 275 F. Supp. 3d at 437; Sattar, 395 F. Supp. 2d at 72 (“The failure to answer honestly must be deliberate; a ‘juror’s good faith failure to respond, though mistaken, [does] not satisfy even the first prong of the test.’” (quoting Shaoul, 41 F.3d at 815)); United States v. Ruggiero, No. 97 Civ. 2925 (HB), 2001 WL 286751, at *3 (S.D.N.Y. Mar. 22, 2001) (rejecting claim of juror misconduct in voir dire, concluding “it is not clear that [the juror’s] failure to respond to the Court’s question was a deliberate attempt at dishonesty, as she only failed to answer the court’s question.”); Perez v. Manhattan Jeep Eagle, No. 92 Civ. 9521 (DLC), 1997 WL 403458, at *5 (S.D.N.Y. July 17, 1997) (“[T]he first prong of the test requires a determination of whether juror number one deliberately lied to the Court during voir dire, or whether his answer was the result of a good faith misunderstanding of the question.”).
In sum, to satisfy the first prong of the governing test, the defendant must establish dishonesty by Juror 50—a deliberate falsehood or deceit, rather than an honest mistake.
b. The Current Record Does Not Support a Finding of Deliberate Falsehood
On the current record, there is no basis for the Court to find that Juror 50 gave any deliberately false answer during voir dire. To be sure, if his public statements regarding being a victim of sexual abuse were truthful,¹⁰ it would appear that Juror 50 answered Question 48
⁹ While some circuits have reached a different result, the Second Circuit’s view appears to be the prevailing one. See, e.g., Fitzgerald v. Greene, 150 F.3d 357, 364 n.3 (4th Cir. 1998) (collecting cases).
¹⁰ It is of course possible that Juror 50’s unsworn public statements were not truthful, while his sworn answers on the questionnaire were. This is a threshold fact that must be determined at a hearing. But for purposes of discussion in this brief, the Government assumes that Juror 50’s public statements on this subject were truthful.
¹⁰ It is of course possible that Juror 50’s unsworn public statements were not truthful, while his sworn answers on the questionnaire were. This is a threshold fact that must be determined at a hearing. But for purposes of discussion in this brief, the Government assumes that Juror 50’s public statements on this subject were truthful.
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DOJ-OGR-00009136
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