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739 KB
Extraction Summary
7
People
3
Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Court filing / legal opinion (case 1:20-cr-00330-pae)
File Size:
739 KB
Summary
This document is page 13 of a court filing (Document 615) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on February 24, 2022. The text outlines legal standards for Rule 33 motions regarding alleged juror misconduct and misrepresentations during voir dire. It cites various precedents (Tanner, McDonough, Shaoul) to establish that courts disfavor post-verdict inquiries and require a strict two-part test to prove that a juror answered dishonestly and that a truthful answer would have resulted in a dismissal for cause.
People (7)
| Name | Role | Context |
|---|---|---|
| Ferguson | Legal Precedent |
Cited in case law regarding Rule 33 motions.
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| Tanner | Legal Precedent |
Cited in Tanner v. United States regarding juror conduct.
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| Ianniello | Legal Precedent |
Cited regarding consequences of post-verdict inquiries.
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| McDonough | Legal Precedent |
Cited in McDonough Power Equip., Inc. v. Greenwood regarding the two-part test for juror misrepresentation.
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| Greenwood | Legal Precedent |
Cited in McDonough Power Equip., Inc. v. Greenwood.
|
| Shaoul | Legal Precedent |
Cited regarding the conjunctive requirements for a new trial.
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| Stewart | Legal Precedent |
Cited in United States v. Stewart regarding hypothetical strikes for cause.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Supreme Court |
Referenced for explanation on juror misconduct inquiries.
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| Second Circuit |
Referenced for cautioning against post-verdict inquiries and defining requirements.
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| DOJ |
Department of Justice Office of General Review stamp in footer.
|
Key Quotes (4)
"The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would be a manifest injustice."Source
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Quote #1
"Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first time . . . after the verdict, seriously disrupt the finality of the process."Source
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Quote #2
"The Second Circuit has cautioned that 'post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation...'"Source
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Quote #3
"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
DOJ-OGR-00009132.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,221 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 13 of 49
original). “The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would
be a manifest injustice.” Ferguson, 246 F.3d at 134.
be a manifest injustice.” Ferguson, 246 F.3d at 134.
Courts strongly disfavor post-verdict inquiries into juror conduct. As the Supreme Court
explained: “Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first
time . . . after the verdict, seriously disrupt the finality of the process. Moreover, full and frank
discussion in the jury room, jurors’ willingness to return an unpopular verdict, and the
community’s trust in a system that relies on the decisions of laypeople would all be undermined
by a barrage of post-verdict scrutiny of juror conduct.” Tanner v. United States, 483 U.S. 107,
120-21 (1987) (citations omitted). The Second Circuit has cautioned that “post-verdict inquiries
may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation,
burdening courts with meritless applications, increasing temptation for jury tampering and creating
uncertainty in jury verdicts.” Ianniello, 866 F.2d at 543.
explained: “Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first
time . . . after the verdict, seriously disrupt the finality of the process. Moreover, full and frank
discussion in the jury room, jurors’ willingness to return an unpopular verdict, and the
community’s trust in a system that relies on the decisions of laypeople would all be undermined
by a barrage of post-verdict scrutiny of juror conduct.” Tanner v. United States, 483 U.S. 107,
120-21 (1987) (citations omitted). The Second Circuit has cautioned that “post-verdict inquiries
may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation,
burdening courts with meritless applications, increasing temptation for jury tampering and creating
uncertainty in jury verdicts.” Ianniello, 866 F.2d at 543.
A defendant seeking Rule 33 relief based on alleged juror misrepresentations during voir
dire must satisfy a two-part test: “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.” McDonough Power Equip., Inc. v. Greenwood,
464 U.S. 548, 556 (1984). The Second Circuit has held that these two requirements are
conjunctive: “in order to obtain a new trial, a defendant must show both that a juror gave a
dishonest answer, and that the correct answer would have provided a basis for the defendant to
challenge the juror for cause.” Shaoul, 41 F.3d at 816 (emphasis in original). The first prong
requires a deliberate misconduct, not an honest mistake. See id.; see also Part II.B.1.a, infra. The
second prong requires the Court to determine whether, if the juror had answered truthfully, it would
have granted a hypothetical strike for cause. See United States v. Stewart, 433 F.3d 273, 304 (2d
dire must satisfy a two-part test: “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.” McDonough Power Equip., Inc. v. Greenwood,
464 U.S. 548, 556 (1984). The Second Circuit has held that these two requirements are
conjunctive: “in order to obtain a new trial, a defendant must show both that a juror gave a
dishonest answer, and that the correct answer would have provided a basis for the defendant to
challenge the juror for cause.” Shaoul, 41 F.3d at 816 (emphasis in original). The first prong
requires a deliberate misconduct, not an honest mistake. See id.; see also Part II.B.1.a, infra. The
second prong requires the Court to determine whether, if the juror had answered truthfully, it would
have granted a hypothetical strike for cause. See United States v. Stewart, 433 F.3d 273, 304 (2d
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