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625 KB
Extraction Summary
4
People
2
Organizations
0
Locations
4
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
625 KB
Summary
This legal document is a court's analysis of a defendant's (Maxwell's) challenge to the impartiality of a juror, Juror 50. The court finds Juror 50's testimony credible and determines that his inadvertent nondisclosure about past sexual abuse does not constitute deliberate lying to be selected for the jury. The court rejects the defendant's argument that similarities between the juror's personal history and the case issues warrant a finding of implied bias, distinguishing this situation from other legal precedents.
People (4)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
The subject of the legal analysis, whose testimony and nondisclosure on a questionnaire are being evaluated by the Co...
|
| Maxwell | Defendant |
The Defendant in the case, who is arguing that Juror 50 was biased and should not have been selected.
|
| Sampson |
Mentioned in the case citation Sampson v. United States.
|
|
| Daugerdas |
Mentioned in a case citation being quoted by the Defendant.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The judicial body making findings about Juror 50's credibility and analyzing the Defendant's legal arguments.
|
| United States | government agency |
Party in the case citation Sampson v. United States.
|
Timeline (4 events)
A voir dire hearing in the Sampson v. United States case where a juror told a 'litany of lies'.
A bank robbery case mentioned as part of the Sampson v. United States citation, where defendants threatened bank tellers at gunpoint.
Relationships (1)
The Defendant is challenging the impartiality of Juror 50, who served on the jury for the Defendant's trial. The document details the Defendant's arguments for why Juror 50 should have been disqualified.
Key Quotes (3)
"litany of lies"Source
— The Court (describing a juror in the Sampson case)
(Used to describe the falsehoods told by a juror in the separate Sampson v. United States case, contrasting that juror's actions with Juror 50's.)
DOJ-OGR-00020974.jpg
Quote #1
"similarities between [his] personal experiences . . . and the issues being litigated."Source
— The Defendant (Maxwell)
(Quoted from the Defendant's brief as the basis for the contention that Juror 50 was biased.)
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Quote #2
"that every person who has been a victim of sexual assault or sexual abuse was subject to a ‘mandatory’ challenge for cause based on implied bias."Source
— The Defendant (Maxwell)
(An argument that the Defendant (Maxwell) is noted to have 'expressly disavowed'.)
DOJ-OGR-00020974.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,157 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page148 of 221
A-348
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 31 of 40
A-348
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 31 of 40
aspect of Questions 48 and 49. As he repeatedly explained, he never expected or even hoped to be selected. The Court finds Juror 50’s testimony to be credible, forthright, and responsive and does not find as a factual matter that Juror 50 deliberately lied in order to be selected as a juror.
The Defendant’s reliance on Sampson v. United States, 724 F.3d 150 (1st Cir. 2013), is similarly unavailing. See Maxwell Post-Hearing Br. at 11. There, a juror failed to disclose that her husband had previously threatened her with a shotgun during jury selection for a bank robbery case in which the defendants threatened the bank tellers at gunpoint. However, the juror had told a “litany of lies” during voir dire bearing on a number of issues, including her daughter’s incarceration and her own substance abuse issues. Id. at 161–62, 168. By contrast, Juror 50’s inadvertent nondisclosure, while implicating multiple questions on the questionnaire, stems only from his experience of sexual abuse.
Second, the Defendant contends that Juror 50 was biased due to the “similarities between [his] personal experiences . . . and the issues being litigated.” Maxwell Br. at 30 (quoting Daugerdas, 867 F. Supp. 2d at 472). She expressly disavows arguing “that every person who has been a victim of sexual assault or sexual abuse was subject to a ‘mandatory’ challenge for cause based on implied bias.” Maxwell Reply at 17. Distancing from that position is necessary— again, it is not the law that an individual with a history of sexual abuse cannot serve as a fair and impartial juror. Rather, the Defendant finesses the argument by saying that Juror 50’s personal history is sufficiently similar to the issues at trial so as to warrant a mandatory finding of implied bias, or alternatively, a discretionary finding of inferred bias, and points to Juror 50’s testimony and post-trial statements as evidence that these purported similarities made him biased. Maxwell Br. at 31–32; Maxwell Post-Hearing Br. at 5–6.
The Defendant’s reliance on Sampson v. United States, 724 F.3d 150 (1st Cir. 2013), is similarly unavailing. See Maxwell Post-Hearing Br. at 11. There, a juror failed to disclose that her husband had previously threatened her with a shotgun during jury selection for a bank robbery case in which the defendants threatened the bank tellers at gunpoint. However, the juror had told a “litany of lies” during voir dire bearing on a number of issues, including her daughter’s incarceration and her own substance abuse issues. Id. at 161–62, 168. By contrast, Juror 50’s inadvertent nondisclosure, while implicating multiple questions on the questionnaire, stems only from his experience of sexual abuse.
Second, the Defendant contends that Juror 50 was biased due to the “similarities between [his] personal experiences . . . and the issues being litigated.” Maxwell Br. at 30 (quoting Daugerdas, 867 F. Supp. 2d at 472). She expressly disavows arguing “that every person who has been a victim of sexual assault or sexual abuse was subject to a ‘mandatory’ challenge for cause based on implied bias.” Maxwell Reply at 17. Distancing from that position is necessary— again, it is not the law that an individual with a history of sexual abuse cannot serve as a fair and impartial juror. Rather, the Defendant finesses the argument by saying that Juror 50’s personal history is sufficiently similar to the issues at trial so as to warrant a mandatory finding of implied bias, or alternatively, a discretionary finding of inferred bias, and points to Juror 50’s testimony and post-trial statements as evidence that these purported similarities made him biased. Maxwell Br. at 31–32; Maxwell Post-Hearing Br. at 5–6.
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DOJ-OGR-00020974
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