DOJ-OGR-00010311.jpg
764 KB
Extraction Summary
8
People
2
Organizations
3
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
764 KB
Summary
This legal document argues that Juror 50 was incapable of being impartial due to his own past trauma of childhood sexual abuse, which was highly similar to that of the victims in the case. The filing cites multiple legal precedents where jurors were dismissed or new trials were granted for failing to disclose such biasing personal experiences. The document further contends that Juror 50's decision to speak to the international press after the trial to 'tell his story' demonstrates his deep identification with the victims and confirms his bias.
People (8)
| Name | Role | Context |
|---|---|---|
| Bobbi C. Sternheim | Attorney |
Mentioned in the header under "LAW OFFICES OF BOBBI C. STERNHEIM".
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| Juror 50 | Juror |
The subject of the legal argument, who allegedly experienced traumatic childhood sexual abuse similar to the trial vi...
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| Daugerdas |
Mentioned in the case citation 'Daugerdas, 867 F. Supp. 2d at 472'.
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| Sampson |
Mentioned in the case citations 'United States v. Sampson, 820 F. Supp. 2d 151' and 'Sampson 724 F.3d at 167'.
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| Ashfar |
Mentioned in the case citation 'State v. Ashfar, 196 A.3d 93, 94-97'.
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| Torres |
Mentioned in the case citation 'Torres, 128 F.3d at 47-48'.
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| Burton |
Mentioned in the case citation 'Burton v. Johnson, 948 F.2d 1150 1159'.
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| Johnson |
Mentioned in the case citation 'Burton v. Johnson, 948 F.2d 1150 1159'.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| LAW OFFICES OF BOBBI C. STERNHEIM | company |
Appears in the header of the document.
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| international press | media |
Juror 50 spoke to multiple members of the international press after the trial.
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Timeline (3 events)
Relationships (1)
The document argues that Juror 50 'closely identified with the victims in this case' because he experienced 'the same traumatic childhood sexual abuse that the trial victims did, with many of the same surrounding circumstances'.
Key Quotes (4)
"Courts imply bias ‘when there are similarities between the personal experiences of the juror and the issues being litigated.’"Source
— United States v. Sampson
(Quoted to support the argument that Juror 50's similar experiences imply bias.)
DOJ-OGR-00010311.jpg
Quote #1
"It would be natural for a juror who had been the victim of [the same crime] to harbor bias against a defendant accused of such a crime."Source
— Sampson
(Quoted to argue that a juror with a similar victim experience would naturally be biased.)
DOJ-OGR-00010311.jpg
Quote #2
"tell his story"Source
— Juror 50 (paraphrased)
(Describing Juror 50's motivation for speaking to the international press after the trial.)
DOJ-OGR-00010311.jpg
Quote #3
"I don’t tell very many people."Source
— Juror 50
(A quote from Juror 50's testimony at a hearing, used to contrast his usual reserve with his decision to speak to the press, highlighting his alleged bias.)
DOJ-OGR-00010311.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,296 characters)
Case 1:20-cr-00330-PAE Document 649 Filed 03/15/22 Page 5 of 12
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
contrast sharply with other jurors who answered “Yes” to Question 48 and were not struck for cause, but who disclosed incidents that were not directly analogous to the facts presented at trial.
In this situation, where Juror 50 experienced the same traumatic childhood sexual abuse that the trial victims did, with many of the same surrounding circumstances, he was not capable of setting his experiences aside and impartially deciding the case solely on the evidence at trial. See Daugerdas, 867 F. Supp. 2d at 472 (“Courts imply bias ‘when there are similarities between the personal experiences of the juror and the issues being litigated.’” (quoting United States v. Sampson, 820 F. Supp. 2d 151, 163-64 (D. Mass. 2011)); Sampson 724 F.3d at 167 (“It would be natural for a juror who had been the victim of [the same crime] to harbor bias against a defendant accused of such a crime.”). Had this information come to light during voir dire, Juror 50 would have been struck for cause. See Motion at 30-38; Sampson, 724 F.3d at 167 (affirming grant of new trial when juror in a gunpoint bank robbery case did not disclose that she had been threatened by her husband with a gun); State v. Ashfar, 196 A.3d 93, 94-97 (N.H. 2018) (affirming grant of new trial when juror in child sexual assault case did not disclose that he was sexually assaulted by a babysitter when he was five or six years old); Torres, 128 F.3d at 47-48 (affirming for cause strike of juror in a structuring case who did not disclose she had engaged in similar structuring activity herself); Burton v. Johnson, 948 F.2d 1150 1159 (10th Cir. 1991) (affirming grant of new trial when juror in murder case involving domestic violence did not disclose she was living in similarly abusive circumstances at the time of trial).
Furthermore, Juror 50’s decision to speak to multiple members of the international press after trial to “tell his story” shows how closely he identified with the victims in this case and reveals his bias. Juror 50 testified at the Hearing that he usually does not share his experience of sexual abuse. (Tr. 22) (“I don’t tell very many people.”). Despite his normal reserve, Juror 50
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DOJ-OGR-00010311
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