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Extraction Summary
6
People
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Organizations
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Locations
1
Events
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Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
739 KB
Summary
This legal document, page 13 of a court filing from March 11, 2022, outlines the legal standards and strong judicial disfavor for post-verdict inquiries into juror conduct. Citing precedents from the Supreme Court and the Second Circuit, it explains that such inquiries threaten the finality of verdicts and the integrity of the jury system. The document also details the strict, two-part test a defendant must satisfy to obtain a new trial based on a juror's dishonest answer during voir dire, requiring proof of both dishonesty and that a truthful answer would have warranted a challenge for cause.
People (6)
| Name | Role | Context |
|---|---|---|
| Ferguson |
Cited in the case Ferguson, 246 F.3d at 134.
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| Tanner |
Cited in the case Tanner v. United States, 483 U.S. 107, 120-21 (1987).
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| Ianniello |
Cited in the case Ianniello, 866 F.2d at 543.
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| Greenwood |
Cited in the case McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984).
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| Shaoul |
Cited in the case Shaoul, 41 F.3d at 816.
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| Stewart |
Cited in the case United States v. Stewart, 433 F.3d 273, 304.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Supreme Court | government agency |
Cited as explaining the rationale for disfavoring post-verdict inquiries into juror conduct.
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| Second Circuit | government agency |
Cited for its caution against post-verdict inquiries and its holding on the requirements for a new trial based on jur...
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| McDonough Power Equip., Inc. | company |
A party in the cited case McDonough Power Equip., Inc. v. Greenwood.
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Timeline (1 events)
The document discusses the legal standards for a Rule 33 motion and for seeking relief based on juror misrepresentations during voir dire.
Locations (1)
| Location | Context |
|---|---|
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Mentioned as a party in the case citations Tanner v. United States and United States v. Stewart.
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Key Quotes (5)
"The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would be a manifest injustice."Source
— Ferguson, 246 F.3d at 134
(Quoted to define the standard for a Rule 33 motion.)
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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. 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."Source
— Supreme Court in Tanner v. United States
(Quoted to explain why courts strongly disfavor post-verdict inquiries into juror conduct.)
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Quote #2
"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."Source
— Second Circuit in Ianniello, 866 F.2d at 543
(Quoted as a caution from the Second Circuit regarding the negative effects of post-verdict inquiries.)
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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
— McDonough Power Equip., Inc. v. Greenwood
(Quoted to establish the two-part test for seeking relief based on juror misrepresentations during voir dire.)
DOJ-OGR-00009811.jpg
Quote #4
"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."Source
— Second Circuit in Shaoul, 41 F.3d at 816
(Quoted to emphasize that the two requirements for a new trial based on juror dishonesty are conjunctive.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,215 characters)
Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 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.
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.
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
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