DOJ-OGR-00002327.jpg
729 KB
Extraction Summary
7
People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
729 KB
Summary
This legal document is an argument on behalf of defendant Ms. Maxwell, challenging the composition of the grand jury that indicted her. It cites an analysis by jury expert Jeffrey Martin from a similar case, United States v. Balde, which found significant underrepresentation of Black and Hispanic persons in the White Plains jury wheel. The argument posits that since Ms. Maxwell's grand jury was drawn from the same system, her Sixth Amendment right to a grand jury selected from a fair cross-section of the community was violated.
People (7)
| Name | Role | Context |
|---|---|---|
| Judge Failla | Judge |
Mentioned as the judge presiding over the case United States v. Balde.
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| Jeffrey Martin | Jury composition expert |
Provided an analysis of the racial and ethnic composition of jury wheels for Manhattan and White Plains in the Balde ...
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| Balde | Defendant |
The defendant in the case United States v. Balde, which involved a similar challenge to the jury composition.
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| Ms. Maxwell | Defendant |
The defendant in the current case (1:20-cr-00330-AJN), whose grand jury composition is being challenged.
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| Reyes | Party in a cited case |
Mentioned in the case citation 'Reyes, 934 F. Supp. at 556'.
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| Taylor | Party in a cited case |
Mentioned in the case citation 'Taylor v. Louisiana, 419 U.S. 522, 530 (1975)'.
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| Osorio | Party in a cited case |
Mentioned in the case citation 'United States v. Osorio, 801 F. Supp. 966, 973-74 (D. Conn. 1992)'.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | Government |
A party in the court cases 'United States v. Balde' and 'United States v. Osorio'.
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Timeline (3 events)
2020-11-09
The 'Declaration of Jeffrey Martin in Support of Motion to Dismiss' was filed in the case U.S. v. Balde.
U.S. District Court
Locations (4)
| Location | Context |
|---|---|
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Location of one of the two qualified jury wheels analyzed by Jeffrey Martin.
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Location of one of the two qualified jury wheels analyzed by Jeffrey Martin, which was found to have significant unde...
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Mentioned in the case citation 'Taylor v. Louisiana'.
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Mentioned in the case citation for 'United States v. Osorio', referring to the District of Connecticut.
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Relationships (2)
The document states that 'the defendant in Balde, like Ms. Maxwell, was indicted in June 2020' and that Ms. Maxwell's grand jury was 'presumably drawn from the same wheels' as the one in the Balde case, which faced a 'similar challenge'.
Jeffrey Martin, a 'jury composition expert', provided an analysis for the defendant in the 'United States v. Balde' case.
Full Extracted Text
Complete text extracted from the document (2,110 characters)
Case 1:20-cr-00330-AJN Document 126 Filed 01/25/21 Page 7 of 13
return the questionnaire (and who are found to be qualified as jurors). Id., Art. IV.A. As with the master wheels, two separate qualified jury wheels are maintained: one for Manhattan and one for White Plains. When jurors are needed, names are drawn at random from these wheels, and summonses are sent to those whose names are drawn. Id., Art. IV.C; Reyes, 934 F. Supp. at 556.
In United States v. Balde, a case currently pending in this District before Judge Failla, the defendant recently submitted, in connection with a similar challenge to the use of a White Plains grand jury in a Manhattan case, an analysis from jury composition expert Jeffrey Martin, who analyzed the racial and ethnic composition of the master and qualified jury wheels for Manhattan and White Plains. See Declaration of Jeffrey Martin in Support of Motion to Dismiss, U.S. v. Balde, No. 1:20-cr-00281-KPF, Dkt. No. 61-1 (filed Nov. 9, 2020), Exhibit A (“Martin Decl.”). Because the jury wheels are emptied and refilled only every four years, following a presidential election, and the defendant in Balde, like Ms. Maxwell, was indicted in June 2020, Ms. Maxwell’s grand jury was presumably drawn from the same wheels Mr. Martin analyzed.
Mr. Martin found significant underrepresentation of Black and Hispanic persons within the White Plains qualified jury wheel—not only when compared to the eligible juror population in the Manhattan counties (Martin Decl. ¶¶ 61-62, 69-70), but also when compared to the eligible juror population of the District as a whole (id. ¶¶ 59-60, 67-68).
ARGUMENT
The Sixth Amendment guarantees a criminal defendant a grand jury selected from a fair cross-section of the community. Taylor v. Louisiana, 419 U.S. 522, 530 (1975). Ms. Maxwell’s right under the Sixth Amendment to a grand jury drawn from a fair cross-section of the community applies to the grand jury that indicted her. See, e.g., United States v. Osorio, 801 F. Supp. 966, 973-74 (D. Conn. 1992) (rejecting argument that Sixth Amendment’s fair cross-
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DOJ-OGR-00002327
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