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Extraction Summary
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People
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Organizations
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Locations
3
Events
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Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
672 KB
Summary
This legal document, page 26 of a court filing, provides a detailed legal analysis of the concepts of "implied bias" and "inferred bias" in the context of juror partiality. It distinguishes between the two, defining implied bias as a conclusive presumption for extreme cases and inferred bias as a discretionary finding by the trial court based on a juror's responses. The document relies heavily on precedents from cases like McCoy, Greer, and Torres to establish these legal standards.
People (6)
| Name | Role | Context |
|---|---|---|
| McCoy | Party in a cited legal case |
Cited in 'McCoy, 995 F.3d at 48' and 'McCoy, 995 F.3d at 49' for legal definitions of bias.
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| Greer | Party in a cited legal case |
Cited in 'Greer, 285 F.3d at 172', 'Greer, 285 F.3d at 171', and in a footnote regarding juror partiality.
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| Torres | Party in a cited legal case |
Cited in 'Torres, 128 F.3d at 45', 'Torres, 128 F.3d at 41', and 'Torres, 128 F.3d at 47' for definitions and applica...
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| Wood | Party in a cited legal case |
Cited in 'United States v. Wood, 299 U.S. 123, 133 (1936)' as a source for a legal principle.
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| Haynes | Party in a cited legal case |
Cited in 'see also Haynes, 398 F.2d at 984' as an additional legal reference.
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| Juror 50 | Juror |
Mentioned in a footnote as the subject of a bias determination by the Court.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
Referenced as the body addressing the issues of implied and inferred bias and making a determination about Juror 50.
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| Second Circuit | government agency |
Mentioned in a footnote as the jurisdiction where the law on post-trial allegations of juror partiality is unsettled.
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| DOJ-OGR | government agency |
Appears as part of a document identifier in the footer (DOJ-OGR-00020969).
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Key Quotes (5)
"Implied bias” is “a concept that is reserved for ‘extreme situations,’ warranting a conclusive presumption of bias as a matter of law."Source
— McCoy, 995 F.3d at 48
(Defining the legal standard for implied bias.)
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Quote #1
"attributed to a prospective juror regardless of actual partiality” because the law presumes that “an average person in the position of the juror in controversy would be prejudiced."Source
— Torres, 128 F.3d at 45
(Explaining the rationale behind the concept of implied bias.)
DOJ-OGR-00020969.jpg
Quote #2
"certain highly limited situations where a juror discloses a fact that creates such a high risk of partiality that the law requires the judge to excuse the juror for cause."Source
— Torres, 128 F.3d at 41
(Describing the circumstances under which implied bias applies.)
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Quote #3
"Bias may be inferred when a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias."Source
— Greer, 285 F.3d at 171 (quoting Torres, 128 F.3d at 47)
(Defining the standard for inferred bias, which is distinct from implied bias.)
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Quote #4
"The inquiry is whether the juror’s responses at voir dire “permit an inference that the juror in question would not be able to decide the matter objectively."Source
— Torres, 128 F.3d at 47
(Stating the test for determining inferred bias based on juror questioning.)
DOJ-OGR-00020969.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,426 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page143 of 221
A-343
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 26 of 40
A-343
Case 1:20-cr-00330-AJN Document 653 Filed 04/01/22 Page 26 of 40
based on the purported similarities between his personal history and the issues at trial. Because these arguments overlap, the Court addresses implied and inferred bias together.⁵
“Implied bias” is “a concept that is reserved for ‘extreme situations,’ warranting a conclusive presumption of bias as a matter of law.” McCoy, 995 F.3d at 48 (internal quotations omitted) (quoting Greer, 285 F.3d at 172). Such bias is “attributed to a prospective juror regardless of actual partiality” because the law presumes that “an average person in the position of the juror in controversy would be prejudiced.” Torres, 128 F.3d at 45 (citing United States v. Wood, 299 U.S. 123, 133 (1936)); see also Haynes, 398 F.2d at 984. The category applies to “certain highly limited situations where a juror discloses a fact that creates such a high risk of partiality that the law requires the judge to excuse the juror for cause.” Torres, 128 F.3d at 41. Namely, “jurors who are related to the parties or who were victims” or otherwise involved in the alleged crime itself are impliedly biased. Id. at 45; see also Greer, 285 F.3d at 172.
On the other hand, a finding of inferred bias is a determination within the trial court’s discretion. Greer, 285 F.3d at 171; see also McCoy, 995 F.3d at 49. “Bias may be inferred when a juror discloses a fact that bespeaks a risk of partiality sufficiently significant to warrant granting the trial judge discretion to excuse the juror for cause, but not so great as to make mandatory a presumption of bias.” Greer, 285 F.3d at 171 (quoting Torres, 128 F.3d at 47)). The inquiry is whether the juror’s responses at voir dire “permit an inference that the juror in question would not be able to decide the matter objectively.” Torres, 128 F.3d at 47. If such facts are elicited, “then, just as in the situation of implied bias, the juror’s statements as to his or her ability to be impartial become irrelevant.” Id. However, “a judge may—particularly when
⁵ It is unsettled in the Second Circuit whether implied or inferred bias may serve as the basis for a post-trial allegation of juror partiality. See Greer, 285 F.3d at 172. Because the Court determines that Juror 50 is neither impliedly nor inferably biased, it need not resolve this issue.
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DOJ-OGR-00020969
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