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698 KB
Extraction Summary
5
People
3
Organizations
0
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing / legal opinion
File Size:
698 KB
Summary
This page from a legal filing (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) discusses the legal standard for 'Inferred Bias' in jurors. It argues that even if 'Juror 50' had disclosed a history of sexual abuse during voir dire, the Court would not have automatically dismissed him for cause without further questioning to establish actual partiality. The text cites precedents like *Torres* and *Greer* to support the trial court's discretion in these matters.
People (5)
| Name | Role | Context |
|---|---|---|
| Juror 50 | Juror |
Subject of a bias inquiry regarding non-disclosure of sexual abuse history.
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| The Defendant | Defendant |
Relies on the Torres case precedent (Ghislaine Maxwell, based on case number 1:20-cr-00330-PAE).
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| Torres | Legal Precedent Subject |
Referenced in case law (United States v. Torres) regarding inferred bias.
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| Greer | Legal Precedent Subject |
Referenced in case law regarding trial court discretion.
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| Ploof | Legal Precedent Subject |
Referenced in case law regarding empanelling of a jury.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| District Court |
The court handling the current trial and retaining discretion on juror dismissal.
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| 2d Cir. |
Second Circuit Court of Appeals (legal citation source).
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| DOJ |
Department of Justice (indicated by footer stamp DOJ-OGR).
|
Relationships (1)
Court evaluates Juror 50's potential bias and history of sexual abuse.
Key Quotes (3)
"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."Source
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Quote #1
"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."Source
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Quote #2
"[A] finding of inferred bias is, by definition, within the discretion of the trial court."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,136 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 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))).
“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”).
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,
the district court struck a juror for cause where she had engaged in the structuring of cash deposits,
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DOJ-OGR-00009150
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