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Extraction Summary
4
People
2
Organizations
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Locations
2
Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
699 KB
Summary
This legal document, a page from a court filing dated March 11, 2022, discusses the legal standard for dismissing a juror based on "inferred bias." It cites several precedents, including *Torres*, *Greer*, and *Ploof*, to establish that such a dismissal is at the discretion of the trial court and requires a high standard of proof, typically developed during voir dire. The text argues that the court would not have struck Juror 50 for inferred bias based on a hypothetical disclosure of sexual abuse, and distinguishes the defendant's reliance on the *Torres* case, where a juror was struck for cause due to involvement in structuring cash deposits.
People (4)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
Mentioned in a hypothetical scenario regarding the disclosure of a history of sexual abuse and whether the Court woul...
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| Torres | Party in a legal case |
Cited in the legal case *Torres*, 128 F.3d at 46-47, which is used as a precedent regarding inferred bias and the str...
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| Greer | Party in a legal case |
Cited in the legal case *Greer*, 285 F.3d at 172, as a precedent regarding the trial court's discretion in findings o...
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| Ploof | Party in a legal case (defendant) |
Cited in the legal case *United States v. Ploof*, 464 F.2d 116, which is quoted regarding deference to a trial judge'...
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| district court | government agency |
Mentioned throughout the document as the body that retains discretion to dismiss jurors, evaluates impartiality, and ...
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| United States | government agency |
Mentioned as a party in the cited case *United States v. Ploof*.
|
Timeline (2 events)
Discussion of the legal doctrine of 'inferred bias' in the context of jury selection and dismissal for cause.
In the cited case of Torres, the district court struck a juror for cause because she had engaged in the structuring of cash deposits.
district court
juror
Key Quotes (5)
"a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias."Source
— Torres, 128 F.3d at 46-47
(Defining the circumstances under which a district court can dismiss a juror for cause without meeting the standard for a mandatory presumption of bias.)
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Quote #1
"only after having received responses from the juror that permit an inference that the juror in question would not be able to decide the matter objectively."Source
— Torres, 128 F.3d at 47
(Stating the condition under which a finding of inferred bias is permitted.)
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Quote #2
"[A] finding of inferred bias is, by definition, within the discretion of the trial court."Source
— Greer, 285 F.3d at 172
(Affirming that findings of inferred bias are at the discretion of the trial court.)
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Quote #3
"There are few aspects of a jury trial where we would be less inclined to disturb a trial judge’s exercise of discretion, absent clear abuse, than in ruling on challenges for cause in the empanelling of a jury."Source
— United States v. Ploof, 464 F.2d 116, 118-19 n.4 (2d Cir. 1972)
(Emphasizing the high level of deference given to a trial judge's decisions during jury selection.)
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Quote #4
"must be grounded in facts developed at voir dire"Source
— Torres, 128 F.3d at 47
(Describing the basis required for a finding of inferable bias.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,129 characters)
Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 31 of 49
iii. Inferred Bias
While the category of cases in which bias must be implied or presumed is limited to “exceptional” or “extreme situations,” the district court retains discretion to dismiss a juror for cause when “a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias.” Torres, 128 F.3d at 46-47. This doctrine of “inferred bias” is “closely linked” to the “traditional categories” of actual and implied bias, and a finding of inferred bias is permitted “only after having received responses from the juror that permit an inference that the juror in question would not be able to decide the matter objectively.” Id. at 47. “[A] finding of inferred bias is, by definition, within the discretion of the trial court.” Greer, 285 F.3d at 172. And, as with actual bias, “a district court’s evaluation of the juror’s impartiality is accorded deference.” Id.; see also id. (“There are few aspects of a jury trial where we would be less inclined to disturb a trial judge’s exercise of discretion, absent clear abuse, than in ruling on challenges for cause in the empanelling of a jury.” (quoting United States v. Ploof, 464 F.2d 116, 118-19 n.4 (2d Cir. 1972))).
Here, the record refutes any suggestion that, had Juror 50 disclosed a history of sexual abuse, the Court would have struck him based on a finding of inferred bias. As set forth above, the record is clear that the Court would have in fact conducted targeted follow-up questioning and, absent some indication in such questioning that would have permitted an inference of bias, the Court would not have struck him. See Torres, 128 F.3d at 47 (finding of inferable bias “must be grounded in facts developed at voir dire”).
Torres, upon which the defendant exclusively relies, is not to the contrary. In that case, the district court struck a juror for cause where she had engaged in the structuring of cash deposits,
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DOJ-OGR-00009829
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