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680 KB
Extraction Summary
2
People
3
Organizations
0
Locations
5
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
680 KB
Summary
This legal document outlines the appellate history of a case concerning juror bias. The district court denied a new trial, the court of appeals reversed that decision, and the Supreme Court then reversed the court of appeals, establishing a new, stricter legal standard for when a juror's failure to disclose information during voir dire warrants a new trial. The case was ultimately remanded for an evidentiary hearing under this new standard.
People (2)
| Name | Role | Context |
|---|---|---|
| Juror Payton | Juror |
Mentioned in the context of a legal case where their son's injury in a fire truck explosion was not disclosed, leadin...
|
| Juror Payton's son |
Mentioned as having been injured in an explosion of a fire truck, a fact relevant to the juror bias issue.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| district court | judiciary |
Initially denied a motion for a new trial without a hearing. The case was ultimately remanded back to this court for ...
|
| court of appeals | judiciary |
Reversed the district court's decision, ordering a new trial. Its decision was later reversed by the Supreme Court fo...
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| The Supreme Court | judiciary |
Reversed the court of appeals, established a new legal standard for juror non-disclosure, and remanded the case.
|
Timeline (5 events)
Juror Payton's son was injured in an explosion of a fire truck.
The district court denied a motion for a new trial without holding a hearing.
district court
The court of appeals reversed the district court's decision and ordered a new trial.
court of appeals
The Supreme Court reversed the court of appeals' decision.
The Supreme Court
The Supreme Court remanded the case to the district court for an evidentiary hearing under a new legal standard.
The Supreme Court
Relationships (1)
The text explicitly states 'Juror Payton’s son'.
Key Quotes (5)
"an average prospective juror would have disclosed the information, and that information would have been significant and cogent evidence of the juror’s probable bias, a new trial is required to rectify the failure to disclose it."Source
— the court of appeals
(The legal standard applied by the court of appeals to order a new trial, which was later deemed incorrect by the Supreme Court.)
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Quote #1
"Good faith... irrelevant to the inquiry."Source
— the court
(The court of appeals' view on whether a juror's good faith in failing to disclose information mattered.)
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Quote #2
"to obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause."Source
— the Court
(The correct legal standard established by the Supreme Court for granting a new trial based on juror non-disclosure.)
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Quote #3
"[v]oir dire examination serves to protect [the fair trial] right by exposing possible biases, both known and unknown, on the part of potential jurors"Source
— The court
(The court's emphasis on the purpose of voir dire.)
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Quote #4
"necessity of truthful answers by prospective jurors if [voir dire] is to serve its purpose is obvious."Source
— The Court
(The court's statement on the importance of honesty from jurors during voir dire.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,834 characters)
Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 32 of 66
that Juror Payton’s son had been injured in an explosion of a fire truck. Id. at 551. The
district court denied a motion for a new trial without holding a hearing. Id.
district court denied a motion for a new trial without holding a hearing. Id.
The court of appeals reversed, ordering a new trial instead of remanding for a
hearing. Id. at 551-52. The court of appeals held that if “an average prospective juror
would have disclosed the information, and that information would have been significant
and cogent evidence of the juror’s probable bias, a new trial is required to rectify the
failure to disclose it.” Id. at 552. “Good faith,” said the court, was “irrelevant to the
inquiry.” Id.
hearing. Id. at 551-52. The court of appeals held that if “an average prospective juror
would have disclosed the information, and that information would have been significant
and cogent evidence of the juror’s probable bias, a new trial is required to rectify the
failure to disclose it.” Id. at 552. “Good faith,” said the court, was “irrelevant to the
inquiry.” Id.
The Supreme Court reversed the court of appeals, concluding that it employed the
wrong standard and erred in reaching the merits instead of remanding the case to the
district court for an evidentiary hearing. Id. at 556. As for the correct legal standard, the
Court said that
wrong standard and erred in reaching the merits instead of remanding the case to the
district court for an evidentiary hearing. Id. at 556. As for the correct legal standard, the
Court said that
to obtain a new trial in such a situation, a party must first demonstrate that a
juror failed to answer honestly a material question on voir dire, and then
further show that a correct response would have provided a valid basis for a
challenge for cause.
juror failed to answer honestly a material question on voir dire, and then
further show that a correct response would have provided a valid basis for a
challenge for cause.
Id. The Court remanded to the court of appeals to consider any outstanding issues and,
assuming the judgment wasn’t reversed for other reasons, to remand to the district court
for an evidentiary hearing applying the new legal standard. Id.
assuming the judgment wasn’t reversed for other reasons, to remand to the district court
for an evidentiary hearing applying the new legal standard. Id.
The court emphasized that “[v]oir dire examination serves to protect [the fair trial]
right by exposing possible biases, both known and unknown, on the part of potential
jurors” and that the “necessity of truthful answers by prospective jurors if [voir dire] is to
serve its purpose is obvious.” Id. at 554. The Court did not expressly disavow the court of
right by exposing possible biases, both known and unknown, on the part of potential
jurors” and that the “necessity of truthful answers by prospective jurors if [voir dire] is to
serve its purpose is obvious.” Id. at 554. The Court did not expressly disavow the court of
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