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635 KB
Extraction Summary
3
People
3
Organizations
0
Locations
3
Events
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Relationships
5
Quotes
Document Information
Type:
Court order / legal opinion
File Size:
635 KB
Summary
This document is page 5 of a court order filed on February 25, 2022, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Court denies the Defendant's motion for an immediate new trial based on the current record but determines that an evidentiary hearing is necessary regarding 'Juror 50.' The document discusses the legal standards (McDonough standard, Rule 606) for post-verdict inquiries into juror misconduct, specifically addressing allegations that Juror 50 failed to disclose a history of sexual abuse during voir dire.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'The Defendant' and via 'Maxwell Br.' (Brief); seeking a new trial based on juror misconduct.
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| Juror 50 | Juror |
Juror accused of nondisclosure regarding sexual abuse history; made unsworn statements to media outlets.
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| Alison J. Nathan | Judge (Implied) |
Case number suffix 'AJN' indicates Judge Nathan; referred to as 'The Court'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Second Circuit Court of Appeals |
Cited for legal precedent regarding evidentiary hearings.
|
|
| D.C. Circuit Court of Appeals |
Cited within a legal citation.
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| Department of Justice (DOJ) |
Indicated in the footer stamp 'DOJ-OGR'.
|
Relationships (1)
Defendant arguing for new trial based on Juror 50's misconduct.
Key Quotes (5)
"The Court therefore denies the Defendant’s motion to grant a new trial on the current record."Source
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Quote #1
"resolving the motion now would require the Court to accept as true Juror 50’s unsworn statements made to media outlets."Source
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Quote #2
"Juror 50 deliberately lied in failing to disclose that he was the victim of sexual abuse."Source
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Quote #3
"if any significant doubt as to a juror’s impartiality remains in the wake of objective evidence of false voir dire responses, an evidentiary hearing generally should be held."Source
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Quote #4
"A post-verdict inquiry into juror misconduct is conducted only 'when there is clear, strong, substantial and incontrovertible evidence...'"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,132 characters)
Case 22-1426, Document 78, 06/29/2023, 3536039, Page99 of 217
SA-353
Case 1:20-cr-00330-AJN Document 620 Filed 02/25/22 Page 5 of 21
SA-353
Case 1:20-cr-00330-AJN Document 620 Filed 02/25/22 Page 5 of 21
The Defendant urges this Court to resolve the motion on the papers, without the need for
a hearing. Maxwell Br. at 28. But resolving the motion now would require the Court to accept
as true Juror 50’s unsworn statements made to media outlets. Moreover, in arguing for a new
trial based on the current record, the Defendant relies extensively on statements prohibited from
consideration by Rule 606. E.g., Maxwell Br. at 12–14 (describing Juror 50’s statements in
deliberation and other jurors’ reactions). The Defendant also urges the Court to reach factual
conclusions that are unavailable on the current record; for example, that Juror 50 deliberately
lied in failing to disclose that he was the victim of sexual abuse. See Maxwell Br. at 39–43.
Finally, the Defendant cites no authority—nor is the Court aware of any—in which a court
granted a new trial under the McDonough standard without first conducting an evidentiary
hearing. As the Second Circuit has instructed, “if any significant doubt as to a juror’s
impartiality remains in the wake of objective evidence of false voir dire responses, an
evidentiary hearing generally should be held.” United States v. Stewart, 433 F.3d 273, 306 (2d
Cir. 2006) (citing United States v. Boney, 977 F.2d 624, 634 (D.C. Cir. 1992)). The Court
therefore denies the Defendant’s motion to grant a new trial on the current record.
a hearing. Maxwell Br. at 28. But resolving the motion now would require the Court to accept
as true Juror 50’s unsworn statements made to media outlets. Moreover, in arguing for a new
trial based on the current record, the Defendant relies extensively on statements prohibited from
consideration by Rule 606. E.g., Maxwell Br. at 12–14 (describing Juror 50’s statements in
deliberation and other jurors’ reactions). The Defendant also urges the Court to reach factual
conclusions that are unavailable on the current record; for example, that Juror 50 deliberately
lied in failing to disclose that he was the victim of sexual abuse. See Maxwell Br. at 39–43.
Finally, the Defendant cites no authority—nor is the Court aware of any—in which a court
granted a new trial under the McDonough standard without first conducting an evidentiary
hearing. As the Second Circuit has instructed, “if any significant doubt as to a juror’s
impartiality remains in the wake of objective evidence of false voir dire responses, an
evidentiary hearing generally should be held.” United States v. Stewart, 433 F.3d 273, 306 (2d
Cir. 2006) (citing United States v. Boney, 977 F.2d 624, 634 (D.C. Cir. 1992)). The Court
therefore denies the Defendant’s motion to grant a new trial on the current record.
III. Evidentiary hearing
For the reasons outlined below, the Court determines that a hearing must be held
regarding Juror 50’s alleged nondisclosure during the jury selection process.
regarding Juror 50’s alleged nondisclosure during the jury selection process.
A. Threshold for an evidentiary hearing
Because of the importance of finality of judgments, the threshold for conducting a post-
verdict inquiry is high. A post-verdict inquiry into juror misconduct is conducted only “when
there is clear, strong, substantial and incontrovertible evidence that a specific, nonspeculative
impropriety has occurred which could have prejudiced the trial of a defendant.” United States v.
verdict inquiry is high. A post-verdict inquiry into juror misconduct is conducted only “when
there is clear, strong, substantial and incontrovertible evidence that a specific, nonspeculative
impropriety has occurred which could have prejudiced the trial of a defendant.” United States v.
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DOJ-OGR-00021529
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