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655 KB
Extraction Summary
4
People
2
Organizations
1
Locations
3
Events
0
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
655 KB
Summary
This document is a page from a legal filing that outlines the applicable law for granting a new trial under Federal Rule of Criminal Procedure 33(a). It establishes the high burden of proof on the defendant and explains why post-verdict inquiries into juror conduct are strongly disfavored by the courts. The text cites several key legal precedents to support the argument that protecting the finality of jury verdicts and the integrity of deliberations is paramount.
People (4)
| Name | Role | Context |
|---|---|---|
| McCourty | Defendant |
Mentioned in the case citation United States v. McCourty, 562 F.3d 458, 475 (2d Cir. 2009).
|
| Tanner | Petitioner |
Mentioned in the case citation Tanner v. United States, 483 U.S. 107, 120-21 (1987).
|
| Ianniello | Defendant |
Mentioned in the case citation United States v. Ianniello, 866 F.2d 540, 543 (2d Cir. 1989).
|
| McDonough | Party in a legal case |
Cited as the source for the two-part test for juror misrepresentations during voir dire.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in the legal cases United States v. McCourty, Tanner v. United States, and United States v. Ianniello.
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| Court | government agency |
Refers to a district court and the appellate court (2d Cir.) that have explained the rules and precedents.
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Timeline (3 events)
Discussion of the legal standard for granting a new trial under Federal Rule of Criminal Procedure 33(a).
Discussion of post-verdict inquiries into juror conduct, which are strongly disfavored.
Discussion of the test for relief based on alleged juror misrepresentations during voir dire.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the context of protecting "full and frank discussion in the jury room".
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Key Quotes (5)
"vacate any judgment and grant a new trial if the interest of justice so requires."Source
— Federal Rule of Criminal Procedure 33(a)
(Describing the power of a district court under the rule.)
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Quote #1
"[t]he defendant bears the burden of proving that he is entitled to a new trial under Rule 33, and before ordering a new trial pursuant to Rule 33, a district court must find that there is a real concern that an innocent person may have been convicted."Source
— The Court (citing United States v. McCourty)
(Explaining the high standard a defendant must meet to be granted a new trial.)
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Quote #2
"seriously disrupt the finality of the process."Source
— The Court (citing Tanner v. United States)
(Describing the effect of post-verdict inquiries into juror conduct.)
DOJ-OGR-00021716.jpg
Quote #3
"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
— The Court (citing United States v. Ianniello)
(Listing the negative outcomes of allowing post-verdict inquiries into juror conduct.)
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Quote #4
"demonstrate that a juror failed to answer honestly a material question on voir dire."Source
— The Court (citing McDonough)
(Stating the first part of a two-part test for a defendant seeking relief for alleged juror misrepresentations.)
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Quote #5
Full Extracted Text
Complete text extracted from the document (1,671 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page69 of 93
56
B. Applicable Law
Federal Rule of Criminal Procedure 33(a) permits a district court to “vacate any judgment and grant a new trial if the interest of justice so requires.” As this Court has explained, “[t]he defendant bears the burden of proving that he is entitled to a new trial under Rule 33, and before ordering a new trial pursuant to Rule 33, a district court must find that there is a real concern that an innocent person may have been convicted.” United States v. McCourty, 562 F.3d 458, 475 (2d Cir. 2009).
Post-verdict inquiries into juror conduct are strongly disfavored. Such inquiries “seriously disrupt the finality of the process.” Tanner v. United States, 483 U.S. 107, 120-21 (1987). Permitting “post-verdict scrutiny of juror conduct” would undermine pillars that undergird the jury trial right, including “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.” Id. Such inquiries may instead “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.” United States v. Ianniello, 866 F.2d 540, 543 (2d Cir. 1989).
Accordingly, a defendant seeking Rule 33 relief based on alleged juror misrepresentations during voir dire must satisfy a stringent two-part test. First, a party must “demonstrate that a juror failed to answer honestly a material question on voir dire.” McDonough
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