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Extraction Summary
7
People
3
Organizations
1
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
686 KB
Summary
This legal document, part of case 1:20-cr-00330-PAE filed on February 24, 2022, is a discussion of the legal standard for granting a new trial based on a juror's potentially false statement during voir dire. The filing argues that, according to Second Circuit precedent established in cases like McDonough and Shaoul, the defendant must prove a juror's falsehood was a deliberate and dishonest act, not merely an honest mistake. While arguing the defendant has failed to meet this standard, the Government consents to a limited hearing on the matter.
People (7)
| Name | Role | Context |
|---|---|---|
| Warger | Party in a legal case |
Mentioned in the case citation 'Warger v. Shauers, 574 U.S. 40, 44 (2014)'.
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| Shauers | Party in a legal case |
Mentioned in the case citation 'Warger v. Shauers, 574 U.S. 40, 44 (2014)'.
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| Radonjich | Party in a legal case |
Mentioned in the case citation 'United States v. Radonjich, 1 F.3d 117, 120 (2d Cir. 1993)'.
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| McDonough | Party in a legal case |
Mentioned in reference to the 'McDonough test' and the case citation 'McDonough, 464 U.S. at 555'.
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| Shaoul | Party in a legal case |
Mentioned in the case citation 'Shaoul, 41 F.3d at 815-16'.
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| Nix | Party in a legal case |
Mentioned in the case citation 'United States v. Nix, 275 F. Supp. 3d 420, 437 (W.D.N.Y. 2017)'.
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| McCoy | Party in a legal case |
Mentioned in the case citation 'United States v. McCoy, 995 F.3d 32 (2d Cir. 2021)'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States Government | government agency |
Referred to as 'the Government' and as a party in several court cases ('United States v. ...').
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| Second Circuit | court |
Mentioned as 'Second Circuit precedent' and in case citations as '2d Cir.'.
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| U.S. District Court for the Western District of New York | court |
Referenced in a case citation as '(W.D.N.Y. 2017)'.
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Timeline (1 events)
The document discusses the legal standard for granting a new trial based on a juror's answers during voir dire.
defendant
Government
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the case citation 'United States v. Nix, 275 F. Supp. 3d 420, 437 (W.D.N.Y. 2017)'.
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Relationships (1)
Defendant
→
adversarial
→
Government
The document outlines the legal arguments between the defendant and the Government regarding the defendant's motion for a new trial.
Key Quotes (5)
"the public interest in maintaining both the finality of verdicts and full and free discussion within the confines of the jury room."Source
— Warger v. Shauers
(Quoted to explain the rule promoting finality of verdicts.)
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Quote #1
"[a]n intentionally false answer during voir dire is not a prerequisite to obtaining a new trial."Source
— Defendant
(The defendant's argument, as stated in their memorandum.)
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Quote #2
"In other words, the Court must assess whether [the juror] deliberately lied or consciously deceived the Court, as opposed to providing inaccurate responses as a result of a mistake, misunderstanding or embarrassment."Source
— United States v. Nix
(Quoted to explain the requirement of proving deliberate falsehood by a juror.)
DOJ-OGR-00009134.jpg
Quote #3
"To invalidate the result of a three-week trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give."Source
— McDonough
(Quoted to provide the reasoning behind the rule against overturning verdicts for honest mistakes.)
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Quote #4
"that to obtain a new trial in . . . a situation [where a juror makes a mistaken response to a question], a party must first demonstrate that a juror failed to answer honestly a material question on voir dire,"Source
— Shaoul
(Quoted to describe the holding of the Second Circuit regarding juror responses.)
DOJ-OGR-00009134.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,004 characters)
Case 1:20-cr-00330-PAE Document 615 Filed 02/24/22 Page 15 of 49
See Warger v. Shauers, 574 U.S. 40, 44 (2014). This rule promotes “the public interest in maintaining both the finality of verdicts and full and free discussion within the confines of the jury room.” United States v. Radonjich, 1 F.3d 117, 120 (2d Cir. 1993).
B. Discussion
Based on the current record, the defendant has failed to satisfy either prong of the McDonough test. However, the Government consents to a limited hearing, as set forth in more detail in Part II, infra.
1. The Defendant Has Failed to Satisfy the First Prong of McDonough
a. The Defendant Must Prove a Deliberate Falsehood
The defendant argues that, under the McDonough test, “[a]n intentionally false answer during voir dire is not a prerequisite to obtaining a new trial.” (Def. Mem. at 23). This argument is foreclosed by binding Second Circuit precedent, which requires “dishonesty,” i.e., a deliberate falsehood or deceit, rather than an honest mistake. Shaoul, 41 F.3d at 815-16. “In other words, the Court must assess whether [the juror] deliberately lied or consciously deceived the Court, as opposed to providing inaccurate responses as a result of a mistake, misunderstanding or embarrassment.” United States v. Nix, 275 F. Supp. 3d 420, 437 (W.D.N.Y. 2017) (citing Shaoul, 41 F.3d at 815), aff’d sub nom. United States v. McCoy, 995 F.3d 32 (2d Cir. 2021). That rule exists for good reason: “To invalidate the result of a three-week trial because of a juror’s mistaken, though honest response to a question, is to insist on something closer to perfection than our judicial system can be expected to give.” McDonough, 464 U.S. at 555.
In Shaoul, the Second Circuit considered McDonough and, specifically, its holding ““that to obtain a new trial in . . . a situation [where a juror makes a mistaken response to a question], a party must first demonstrate that a juror failed to answer honestly a material question on voir dire,
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