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Court filing / legal memorandum
File Size:
683 KB
Summary
This document is page 23 (filed page 30) of a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), dated February 24, 2022. The text presents legal arguments regarding juror misconduct during voir dire, citing precedents to argue that a false answer by a juror—whether intentional or inadvertent—that hides bias constitutes structural error requiring a new trial. It references key cases such as United States v. Barnes, United States v. Stewart, and McDonough.
Organizations (3)
| Name | Type | Context |
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| United States District Court |
Implied by case number and filing header.
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| Department of Justice (DOJ) |
Source of the document via Bates stamp DOJ-OGR-00009031.
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| 2d Cir. |
Second Circuit Court of Appeals, cited in legal precedents.
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Timeline (1 events)
Key Quotes (4)
"“A juror’s dishonesty during voir dire undermines a defendant’s right to a fair trial.”"Source
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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
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Quote #2
"When a biased juror deliberates on a jury, structural error occurs, and a new trial is required without a showing of actual prejudice."Source
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Quote #3
"“Intentionally false” juror answers are not a prerequisite to a finding that a defendant’s constitutional right to a fair and impartial jury have been violated."Source
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Full Extracted Text
Complete text extracted from the document (1,806 characters)
Case 1:20-cr-00330-PAE Document 613 Filed 02/24/22 Page 30 of 66
for cause, but also his peremptory challenges.” United States v. Barnes, 604 F.2d 121,
139 (2d Cir. 1979) (internal quotations and citations omitted). “A juror’s dishonesty
during voir dire undermines a defendant’s right to a fair trial.” Daugerdas, 867 F. Supp.
2d at 468; U.S. Const. amend. VI.
139 (2d Cir. 1979) (internal quotations and citations omitted). “A juror’s dishonesty
during voir dire undermines a defendant’s right to a fair trial.” Daugerdas, 867 F. Supp.
2d at 468; U.S. Const. amend. VI.
“[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.” United States v. Stewart,
433 F.3d 273, 303 (2d Cir. 2006) (citing McDonough, 464 U.S. at 556).
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.” United States v. Stewart,
433 F.3d 273, 303 (2d Cir. 2006) (citing McDonough, 464 U.S. at 556).
A defendant need not demonstrate prejudice when a juror gives a false answer to a
material question during voir dire if the juror would have been subject to a challenge for
cause if he had answered honestly. See United States v. Martinez-Salazar, 528 U.S. 304,
316 (2000) (the “seating of any juror who should have been dismissed for cause” “would
require reversal”). When a biased juror deliberates on a jury, structural error occurs, and a
new trial is required without a showing of actual prejudice. See Arizona v. Fulminante,
499 U.S. 279, 307-10 (1991).
material question during voir dire if the juror would have been subject to a challenge for
cause if he had answered honestly. See United States v. Martinez-Salazar, 528 U.S. 304,
316 (2000) (the “seating of any juror who should have been dismissed for cause” “would
require reversal”). When a biased juror deliberates on a jury, structural error occurs, and a
new trial is required without a showing of actual prejudice. See Arizona v. Fulminante,
499 U.S. 279, 307-10 (1991).
B. An intentionally false answer during voir dire is not a prerequisite to
obtaining a new trial.
obtaining a new trial.
“Intentionally false” juror answers are not a prerequisite to a finding that a
defendant’s constitutional right to a fair and impartial jury have been violated.
McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59
(Brennan, J., concurring in judgment). So long as a truthful answer would have subjected
the juror to a challenge for cause based on bias, an inadvertent false answer is just as
defendant’s constitutional right to a fair and impartial jury have been violated.
McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59
(Brennan, J., concurring in judgment). So long as a truthful answer would have subjected
the juror to a challenge for cause based on bias, an inadvertent false answer is just as
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