DOJ-OGR-00002327(1).jpg
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Extraction Summary
8
People
1
Organizations
5
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
729 KB
Summary
This legal document argues that the defendant, Ms. Maxwell, was denied her Sixth Amendment right to a grand jury selected from a fair cross-section of the community. It cites a parallel case, U.S. v. Balde, and an expert analysis by Jeffrey Martin, which found significant underrepresentation of Black and Hispanic individuals in the White Plains jury wheel. Because Ms. Maxwell's grand jury was drawn from the same pool, the document contends this analysis applies to her case as well.
People (8)
| Name | Role | Context |
|---|---|---|
| Reyes |
Mentioned in a case citation: 'Reyes, 934 F. Supp. at 556.'
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| Judge Failla | Judge |
Presiding over the case 'United States v. Balde' in the same District.
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| Balde | Defendant |
Defendant in the case 'United States v. Balde', who made a similar challenge to the grand jury composition.
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| Jeffrey Martin | Jury composition expert |
Provided an analysis of the racial and ethnic composition of jury wheels for the 'Balde' case, which is being referen...
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| Ms. Maxwell | Defendant |
The defendant in the current case (1:20-cr-00330-AJN), whose grand jury is the subject of this argument.
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| Mr. Martin | Jury composition expert |
Referenced as the expert who analyzed the jury wheels and found underrepresentation. Same person as Jeffrey Martin.
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| Taylor |
Mentioned in a case citation: 'Taylor v. Louisiana, 419 U.S. 522, 530 (1975).'
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| Osorio |
Mentioned in a case citation: 'United States v. Osorio, 801 F. Supp. 966, 973-74 (D. Conn. 1992).'
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Mentioned as a party in several court cases, such as 'United States v. Balde' and 'United States v. Osorio'.
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Timeline (4 events)
2020-11-09
The 'Declaration of Jeffrey Martin in Support of Motion to Dismiss' was filed in the case of U.S. v. Balde.
Locations (5)
| Location | Context |
|---|---|
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Location of one of the two qualified jury wheels and the location of a case mentioned.
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Location of one of the two qualified jury wheels, which is the subject of the analysis for underrepresentation.
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Refers to the judicial district where the cases are pending and whose juror population is being analyzed.
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Mentioned in the case citation 'Taylor v. Louisiana'.
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Abbreviation for the District of Connecticut, mentioned in the 'United States v. Osorio' case citation.
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Relationships (3)
Both are defendants in separate cases who were indicted in June 2020 and are challenging the composition of the grand jury drawn from the same jury wheels.
Jeffrey Martin served as a jury composition expert for the defendant in the Balde case, providing an analysis to support a motion to dismiss.
Ms. Maxwell's legal argument relies on the analysis previously conducted by Jeffrey Martin for the Balde case, as her grand jury was drawn from the same wheels Martin analyzed.
Full Extracted Text
Complete text extracted from the document (2,110 characters)
Case 1:20-cr-00330-AJN Document 126 Filed 01/25/21 Page 7 of 13
return the questionnaire (and who are found to be qualified as jurors). Id., Art. IV.A. As with the master wheels, two separate qualified jury wheels are maintained: one for Manhattan and one for White Plains. When jurors are needed, names are drawn at random from these wheels, and summonses are sent to those whose names are drawn. Id., Art. IV.C; Reyes, 934 F. Supp. at 556.
In United States v. Balde, a case currently pending in this District before Judge Failla, the defendant recently submitted, in connection with a similar challenge to the use of a White Plains grand jury in a Manhattan case, an analysis from jury composition expert Jeffrey Martin, who analyzed the racial and ethnic composition of the master and qualified jury wheels for Manhattan and White Plains. See Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S. v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit A (“Martin Decl.”). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell’s grand jury was presumably drawn from the same wheels Mr. Martin analyzed.
Mr. Martin found significant underrepresentation of Black and Hispanic persons within the White Plains qualified jury wheel—not only when compared to the eligible juror population in the Manhattan counties (Martin Decl. ¶¶ 61-62, 69-70), but also when compared to the eligible juror population of the District as a whole (id. ¶¶ 59-60, 67-68).
ARGUMENT
The Sixth Amendment guarantees a criminal defendant a grand jury selected from a fair cross-section of the community. Taylor v. Louisiana, 419 U.S. 522, 530 (1975). Ms. Maxwell’s right under the Sixth Amendment to a grand jury drawn from a fair cross-section of the community applies to the grand jury that indicted her. See, e.g., United States v. Osorio, 801 F. Supp. 966, 973-74 (D. Conn. 1992) (rejecting argument that Sixth Amendment’s fair cross-
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DOJ-OGR-00002327
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