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703 KB
Extraction Summary
13
People
2
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
703 KB
Summary
This legal document is a page from a motion filed on behalf of Ms. Maxwell, arguing that she is entitled to a new trial due to false answers given by Juror No. 50 during jury selection. The central argument is that Maxwell does not need to prove the juror's falsehoods were deliberate, citing several legal precedents to support the claim that even honest mistakes can warrant a new trial to ensure the constitutional right to a fair and impartial jury. The motion criticizes the government's position as a weak attempt to achieve "finality" at the expense of justice.
People (13)
| Name | Role | Context |
|---|---|---|
| Juror No. 50 | Juror |
Mentioned as having publicly admitted to making false answers during voir dire.
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| Ms. Maxwell | Defendant |
The subject of the motion, arguing for a new trial based on Juror No. 50's false answers.
|
| Connick |
Party in the cited case Connick v. Thompson.
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| Thompson |
Party in the cited case Connick v. Thompson.
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| Greenwood |
Party in the cited case McDonough Power Equip. v. Greenwood.
|
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| Zerka |
Party in the cited case Zerka v. Green.
|
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| Green |
Party in the cited case Zerka v. Green.
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| Dyer |
Party in the cited case Dyer v. Calderon.
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| Calderon |
Party in the cited case Dyer v. Calderon.
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| Amirault |
Party in the cited case Amirault v. Fair.
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| Fair |
Party in the cited case Amirault v. Fair.
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| Cannon |
Party in the cited case Cannon v. Lockhart.
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| Lockhart |
Party in the cited case Cannon v. Lockhart.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| McDonough Power Equip. | company |
Party in the cited case McDonough Power Equip. v. Greenwood.
|
| United States | government agency |
Mentioned in the context of its solemn duty to seek justice, referring to the prosecution.
|
Timeline (2 events)
A motion filed on behalf of Ms. Maxwell arguing that she does not have to prove Juror No. 50's voir dire answers were deliberately false to be entitled to a new trial.
Court
Ms. Maxwell
the government
The jury selection process during which Juror No. 50 allegedly provided false answers.
Court
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the context of the government's duty and in case citations (U.S. reports).
|
Relationships (2)
The document outlines a legal dispute between Ms. Maxwell (the defendant) and the government (the prosecution) regarding the fairness of her trial.
The document centers on Ms. Maxwell's motion for a new trial based on allegedly false answers provided by Juror No. 50 during jury selection (voir dire).
Key Quotes (4)
"Prosecutors have a special “duty to seek justice, not merely to convict.”"Source
— Connick v. Thompson, 563 U.S. 51, 65-66 (2011)
(Cited to cast doubt on the government's legal position and emphasize its duty.)
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Quote #1
"Ms. Maxwell does not have to prove that Juror No. 50’s voir dire answers were deliberately false."Source
— The document's author (Ms. Maxwell's defense)
(A section heading summarizing the core legal argument of this part of the motion.)
DOJ-OGR-00009204.jpg
Quote #2
"does not entirely foreclose a party from seeking a new trial on the basis of a prospective juror’s honest, though mistaken, response."Source
— McDonough Power Equip. v. Greenwood
(Cited to counter the government's argument that deliberate falsehood must be proven.)
DOJ-OGR-00009204.jpg
Quote #3
"In extraordinary cases, courts may presume bias based on the circumstances."Source
— Dyer v. Calderon, 151 F.3d 970, 981 (9th Cir. 1998)
(Cited as legal precedent supporting the argument for a new trial.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,074 characters)
Case 1:20-cr-00330-PAE Document 616 Filed 02/24/22 Page 14 of 32
in a “documentary.” Inquiring into the false answers Juror No. 50 has publicly admitted making risks nothing that Juror No. 50 hasn’t already brought on himself.
Ms. Maxwell’s motion has nothing to do with her innocence or guilt. It involves no strategy or artifice by the defense. And it risks no unauthorized inquiry into the jury room. The motion is about one thing, and one thing only: Every person’s constitutional right to a fair and impartial jury. The government hopes to deprive Ms. Maxwell of that right in the name of “finality.”
This Court should disregard the government’s policy arguments, which address arguments and claims Ms. Maxwell is not making. In turn, the government’s policy arguments betray the weakness of its legal position. And they cast significant doubt on the United States solemn duty to seek justice and not merely to convict. Connick v. Thompson, 563 U.S. 51, 65-66 (2011) (“Prosecutors have a special “duty to seek justice, not merely to convict.”).
B. Ms. Maxwell does not have to prove that Juror No. 50’s voir dire answers were deliberately false.
The government insists that Ms. Maxwell is entitled to a new trial only if she can prove that Juror No. 50 deliberately provided false answers during voir dire. Not so.
Contrary to the government’s argument, the decision McDonough Power Equip. v. Greenwood, “does not entirely foreclose a party from seeking a new trial on the basis of a prospective juror’s honest, though mistaken, response.” Zerka v. Green, 49 F.3d 1181, 1186 n.7 (6th Cir. 1995); accord Dyer v. Calderon, 151 F.3d 970, 981 (9th Cir. 1998) (en banc) (“In extraordinary cases, courts may presume bias based on the circumstances.”); Amirault v. Fair, 968 F.2d 1404, 1405-06 (1st Cir. 1992) (“[T]he majority vote in McDonough. . . require[s] a further determination on the question of juror bias even where a juror is found to have been honest. . . .”), cert. denied, 506 U.S. 1000; Cannon v. Lockhart, 850 F.2d 437, 440 (8th Cir.
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DOJ-OGR-00009204
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