DOJ-OGR-00009887.jpg
745 KB
Extraction Summary
10
People
5
Organizations
1
Locations
7
Events
0
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
745 KB
Summary
This legal document, filed on March 11, 2022, is part of a court case involving Ms. Maxwell. The text argues against the government's position by analyzing several legal precedents, including McDonough, Shaoul, Langford, and Greer, concerning the standard for proving juror bias and granting a new trial. The author contends that a deliberate falsehood by a juror is not a prerequisite for a new trial, citing cases that establish a multi-part test where juror dishonesty is one of several factors to consider.
People (10)
| Name | Role | Context |
|---|---|---|
| Haynes |
Mentioned as a party in the case Haynes v. Williams.
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| Williams |
Mentioned as a party in the case Haynes v. Williams.
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| McGohey |
Mentioned as a party in the case P. Beiersdorf & Co. v. McGohey.
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| Shaoul |
Mentioned in the context of the legal precedent set by the case Shaoul.
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| McDonough |
Mentioned in the context of the legal precedent set by the case McDonough.
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| Langford |
Mentioned in the context of the legal precedent set by the case Langford.
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| Ms. Maxwell |
A party in the current legal proceedings, advocating for a specific reading of the McDonough precedent.
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| Mansfield |
Mentioned as a party in the case United States v. Mansfield.
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| Stewart |
Mentioned in the context of the legal precedent set by the case Stewart.
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| Greer |
Mentioned as a party in the case United States v. Greer.
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Organizations (5)
| Name | Type | Context |
|---|---|---|
| Texaco Inc. | company |
Mentioned as a party in the case Texaco Inc. v. Louisiana Land & Exploration Co.
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| Louisiana Land & Exploration Co. | company |
Mentioned as a party in the case Texaco Inc. v. Louisiana Land & Exploration Co.
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| P. Beiersdorf & Co. | company |
Mentioned as a party in the case P. Beiersdorf & Co. v. McGohey.
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| United States | government agency |
Mentioned as a party in the cases United States v. Mansfield and United States v. Greer.
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| DOJ | government agency |
Appears in the footer as part of a document identifier (DOJ-OGR-00009887).
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Timeline (7 events)
1993
Decision in the case Texaco Inc. v. Louisiana Land & Exploration Co.
5th Cir.
Locations (1)
| Location | Context |
|---|---|
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Mentioned as the district court for the case United States v. Mansfield.
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Key Quotes (3)
"[W]hen faced with an intra-circuit conflict, a panel should follow earlier, settled precedent over a subsequent deviation therefrom."Source
— Haynes v. Williams
(Quoted as legal precedent regarding how courts should handle conflicting decisions within the same circuit.)
DOJ-OGR-00009887.jpg
Quote #1
"a party alleging unfairness based on undisclosed juror bias must demonstrate 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
(Quoted from the Stewart case to describe the two-part test for proving juror bias without requiring proof of a deliberate falsehood.)
DOJ-OGR-00009887.jpg
Quote #2
"McDonough establishes a multi-part test in which a juror’s dishonesty is among the ‘factors to be considered’ in the ultimate determination of bias."Source
— Greer
(Quoted from the Greer case to explain that the McDonough precedent establishes a test where juror dishonesty is a factor, not the sole determinant, in assessing bias.)
DOJ-OGR-00009887.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,182 characters)
Case 1:20-cr-00330-PAE Document 644 Filed 03/11/22 Page 18 of 32
another.” (quoting Texaco Inc. v. Louisiana Land & Exploration Co., 995 F.2d 43, 44 (5th Cir. 1993))); see also Haynes v. Williams, 88 F.3d 898, 900 n. 4 (10th Cir. 1996) (“[W]hen faced with an intra-circuit conflict, a panel should follow earlier, settled precedent over a subsequent deviation therefrom.”); P. Beiersdorf & Co. v. McGohey, 187 F.2d 14, 15 (2d Cir. 1951) (when there is an intra-circuit conflict, courts must follow the earlier decision).
Of course, this Court need not conclude that Shaoul is inconsistent with McDonough and Langford in order to reject the government’s argument. As described above, Shaoul does not address the reading of McDonough that Ms. Maxwell advocates for here, since it did not discuss or even cite the McDonough concurring opinions.
Moreover, Second Circuit cases following Langford and Shaoul have reaffirmed that a deliberate falsehood is not a prerequisite to a new trial. Cf. United States v. Mansfield, 2019 WL 3858511, at *4 & n.4 (D. Colo. No. 18-cr-00466-PAB, Aug. 16, 2019) (in face of intra-circuit conflict, following first-decided case and noting that subsequent cases had followed first decision as was well). In Stewart, for example, decided in 2006, the Court cited and quoted McDonough and yet did not require a deliberately false answer, stating instead that “a party alleging unfairness based on undisclosed juror bias must demonstrate 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 (citing McDonough, 464 U.S. at 556).
Then there’s United States v. Greer, which reads McDonough and Langford just as Ms. Maxwell reads them, even while citing Shaoul. United States v. Greer, 285 F.3d 158, 171-72 (2d Cir. 2002). As the Court explained in Greer, “McDonough establishes a multi-part test in which a juror’s dishonesty is among the ‘factors to be considered’ in the ultimate determination of bias. . . .” Id. at 173 (citing Langford, 990 F.2d at 68-70 (emphasis added)). Thus, just as Ms. Maxwell
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DOJ-OGR-00009887
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