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Extraction Summary
5
People
2
Organizations
0
Locations
1
Events
3
Relationships
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Quotes
Document Information
Type:
Court filing / legal brief
File Size:
770 KB
Summary
This document page is from a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on March 11, 2022. It presents legal arguments regarding juror misconduct and the standard for obtaining a new trial, citing the Supreme Court case *McDonough Power Equipment, Inc. v. Greenwood*. The text quotes concurring opinions by Justices Blackmun and Brennan to argue that a juror's intentional dishonesty is not strictly required to order a post-trial hearing on bias.
People (5)
| Name | Role | Context |
|---|---|---|
| Justice Blackmun | Supreme Court Justice |
Wrote a concurring opinion in McDonough; quoted extensively regarding juror impartiality and post-trial hearings.
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| Justice Stevens | Supreme Court Justice |
Joined Justice Blackmun's opinion.
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| Justice O'Connor | Supreme Court Justice |
Joined Justice Blackmun's opinion; cited in Smith v. Phillips.
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| Justice Brennan | Supreme Court Justice |
Recognized that juror bias is rarely admitted by the juror; quoted regarding inferring bias from circumstances.
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| Justice Marshall | Supreme Court Justice |
Joined Justice Brennan's opinion.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Department of Justice |
Indicated by footer stamp DOJ-OGR-00009725
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| U.S. District Court |
Implied by case header 1:20-cr-00330-PAE (SDNY)
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Timeline (1 events)
Relationships (3)
Writing for himself and Justices Stevens and O’Connor
Writing for himself and Justices Stevens and O’Connor
Justice Brennan joined by Justice Marshall recognized that...
Key Quotes (4)
"an intentionally false answer is not a prerequisite to obtaining a new trial."Source
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Quote #1
"regardless of whether a juror’s answer is honest or dishonest, it remains within a trial court’s option, in determining whether a jury was biased, to order a post-trial hearing"Source
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Quote #2
"the bias of a juror will rarely be admitted by the juror himself"Source
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Quote #3
"bias “must be inferred from surrounding facts and circumstances.”"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,123 characters)
Case 1:20-cr-00330-PAE Document 642 Filed 03/11/22 Page 33 of 66
appeals’ statement that the good faith of a potential juror was “irrelevant” to the inquiry.
Id. at 553-56.
Id. at 553-56.
There were two concurring opinions in McDonough, joined by a total of five
justices, which make clear that an intentionally false answer is not a prerequisite to
obtaining a new trial. Writing for himself and Justices Stevens and O’Connor, Justice
Blackmun said:
justices, which make clear that an intentionally false answer is not a prerequisite to
obtaining a new trial. Writing for himself and Justices Stevens and O’Connor, Justice
Blackmun said:
I agree with the Court that the proper inquiry in this case is whether the
defendant had the benefit of an impartial trier of fact. I also agree that, in
most cases, the honesty or dishonesty of a juror’s response is the best initial
indicator of whether the juror in fact was impartial. I therefore join the
Court’s opinion, but I write separately to state that I understand the Court’s
holding not to foreclose the normal avenue of relief available to a party who
is asserting that he did not have the benefit of an impartial jury. Thus,
regardless of whether a juror’s answer is honest or dishonest, it remains
within a trial court’s option, in determining whether a jury was biased, to
order a post-trial hearing at which the movant has the opportunity to
demonstrate actual bias or, in exceptional circumstances, that the facts are
such that bias is to be inferred. See Smith v. Phillips, 455 U.S. 209, 215-16
(O’Connor, J., concurring).
defendant had the benefit of an impartial trier of fact. I also agree that, in
most cases, the honesty or dishonesty of a juror’s response is the best initial
indicator of whether the juror in fact was impartial. I therefore join the
Court’s opinion, but I write separately to state that I understand the Court’s
holding not to foreclose the normal avenue of relief available to a party who
is asserting that he did not have the benefit of an impartial jury. Thus,
regardless of whether a juror’s answer is honest or dishonest, it remains
within a trial court’s option, in determining whether a jury was biased, to
order a post-trial hearing at which the movant has the opportunity to
demonstrate actual bias or, in exceptional circumstances, that the facts are
such that bias is to be inferred. See Smith v. Phillips, 455 U.S. 209, 215-16
(O’Connor, J., concurring).
Id. at 556-57 (Blackmun, J., concurring (emphasis added)). This was the entirety of
Justice Blackmun’s dissent. Id.
Justice Blackmun’s dissent. Id.
For his part, Justice Brennan joined by Justice Marshall recognized that “the bias
of a juror will rarely be admitted by the juror himself, ‘partly because the juror may have
an interest in concealing his own bias and partly because the juror may be unaware of
it.’” Id. at 558 (Brennan, J., concurring in judgment) (quoting majority opinion).
of a juror will rarely be admitted by the juror himself, ‘partly because the juror may have
an interest in concealing his own bias and partly because the juror may be unaware of
it.’” Id. at 558 (Brennan, J., concurring in judgment) (quoting majority opinion).
“Necessarily,” then, Justice Brennan explained, bias “must be inferred from surrounding
facts and circumstances.” Id. “Whether the juror answered a particular question on voir
dire honestly or dishonestly, or whether an inaccurate answer was inadvertent or
facts and circumstances.” Id. “Whether the juror answered a particular question on voir
dire honestly or dishonestly, or whether an inaccurate answer was inadvertent or
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DOJ-OGR-00009725
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