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599 KB
Extraction Summary
7
People
5
Organizations
1
Locations
0
Events
0
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
599 KB
Summary
This legal document excerpt discusses the standards for setting aside a jury verdict and granting a new trial, particularly focusing on juror nondisclosure during voir dire examination. It cites several Supreme Court and Circuit Court cases, establishing that such motions are disfavored and require a high burden of proof, specifically demonstrating a juror's dishonest answer to a material question that would have led to a challenge for cause.
People (7)
| Name | Role | Context |
|---|---|---|
| Smith | Party in a legal case |
Cited in Smith v. Phillips
|
| Phillips | Party in a legal case |
Cited in Smith v. Phillips
|
| Ventura | Party in a legal case |
Cited in United States v. Ventura
|
| Ianniello | Party in a legal case |
Cited in United States v. Ianniello
|
| Archer | Party in a legal case |
Cited in United States v. Archer
|
| Ferguson | Party in a legal case |
Cited in United States v. Ferguson
|
| Shaoul | Party in a legal case |
Cited in United States v. Shaoul
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| McDonough Power Equip., Inc. | Company |
Party in McDonough Power Equip., Inc. v. Greenwood
|
| United States | Government agency |
Party in multiple legal cases (United States v. Ventura, United States v. Ianniello, United States v. Archer, United ...
|
| Federal Rule of Criminal Procedure | Legal framework |
Rule 33 is discussed regarding vacating judgments and granting new trials
|
| Second Circuit | Court |
Cited as having cautioned district courts regarding granting new trials
|
| Supreme Court | Court |
Cited as having held the standard for new trials based on juror nondisclosure in McDonough
|
Locations (1)
| Location | Context |
|---|---|
|
Southern District of New York, cited in United States v. Ventura
|
Key Quotes (6)
"willing to decide the case solely on the evidence before it."Source
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Quote #1
"expos[es] possible biases, both known and unknown, on the part of potential jurors,"Source
DOJ-OGR-00020955.jpg
Quote #2
"disfavored"Source
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Quote #3
"vacate any judgment and grant a new trial if the interest of justice so requires,"Source
DOJ-OGR-00020955.jpg
Quote #4
"such action must be done ‘sparingly’ and in ‘the most extraordinary circumstances.’"Source
DOJ-OGR-00020955.jpg
Quote #5
"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
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Quote #6
Full Extracted Text
Complete text extracted from the document (1,986 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page129 of 221
A-329
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 12 of 40
A-329
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 12 of 40
willing to decide the case solely on the evidence before it.” Smith v. Phillips, 455 U.S. 209, 217
(1982). One important means of ensuring an impartial jury is voir dire examination, which
“expos[es] possible biases, both known and unknown, on the part of potential jurors,” by
eliciting information under oath. McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548,
554 (1984).
Once a jury has returned a verdict, a motion to set aside that verdict is “disfavored” and
the moving party must overcome an “exacting hurdle” of proof. United States v. Ventura, No.
09-CR-1015 (JGK), 2014 WL 259655, at *3 (S.D.N.Y. Jan. 21, 2014); see United States v.
Ianniello, 866 F.2d 540, 543 (2d Cir. 1989). And while Federal Rule of Criminal Procedure 33
permits a court to “vacate any judgment and grant a new trial if the interest of justice so
requires,” Fed. R. Crim. P. 33(a), the Second Circuit has cautioned district courts that “such
action must be done ‘sparingly’ and in ‘the most extraordinary circumstances.’” United States v.
Archer, 977 F.3d 181, 187 (2d Cir. 2020) (quoting United States v. Ferguson, 246 F.3d 129, 134
(2d Cir. 2001)).
The parties agree that a defendant’s Rule 33 motion premised on a juror’s alleged
nondisclosure during voir dire is governed by McDonough Power Equipment, Inc. v.
Greenwood, 464 U.S. 548 (1984). Maxwell Br. at 22–28, Dkt. No. 642; Gov. Br. at 11, Dkt. No.
643. In McDonough, the Supreme Court held that to obtain a new trial on the basis of juror
nondisclosure during voir dire, “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, 464 U.S. at 556; see also
United States v. Shaoul, 41 F.3d 811, 815–16 (2d Cir. 1994).
(1982). One important means of ensuring an impartial jury is voir dire examination, which
“expos[es] possible biases, both known and unknown, on the part of potential jurors,” by
eliciting information under oath. McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548,
554 (1984).
Once a jury has returned a verdict, a motion to set aside that verdict is “disfavored” and
the moving party must overcome an “exacting hurdle” of proof. United States v. Ventura, No.
09-CR-1015 (JGK), 2014 WL 259655, at *3 (S.D.N.Y. Jan. 21, 2014); see United States v.
Ianniello, 866 F.2d 540, 543 (2d Cir. 1989). And while Federal Rule of Criminal Procedure 33
permits a court to “vacate any judgment and grant a new trial if the interest of justice so
requires,” Fed. R. Crim. P. 33(a), the Second Circuit has cautioned district courts that “such
action must be done ‘sparingly’ and in ‘the most extraordinary circumstances.’” United States v.
Archer, 977 F.3d 181, 187 (2d Cir. 2020) (quoting United States v. Ferguson, 246 F.3d 129, 134
(2d Cir. 2001)).
The parties agree that a defendant’s Rule 33 motion premised on a juror’s alleged
nondisclosure during voir dire is governed by McDonough Power Equipment, Inc. v.
Greenwood, 464 U.S. 548 (1984). Maxwell Br. at 22–28, Dkt. No. 642; Gov. Br. at 11, Dkt. No.
643. In McDonough, the Supreme Court held that to obtain a new trial on the basis of juror
nondisclosure during voir dire, “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, 464 U.S. at 556; see also
United States v. Shaoul, 41 F.3d 811, 815–16 (2d Cir. 1994).
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