{
  "document_metadata": {
    "page_number": "18",
    "document_number": "Case 1:17-cr-00383-PAC Document 1859 Filed 03/22/21 Page 18 of 20",
    "date": "03/22/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "chance.\" (Schulte Br. at 17.) But the Court will not assume or infer that this District has been operating under an intentionally discriminatory Jury Plan since 2009. See Rioux, 97 F.3d at 659 (rejecting Equal Protection challenge due to lack of evidence showing intentional discrimination). Therefore, the Defendant's Equal Protection claim must be rejected.\n\nIII. JSSA\n\nSchulte's remaining claims arise under the JSSA. To succeed on these claims, he must demonstrate a \"substantial failure to comply\" with the JSSA's provisions. LaChance, 788 F.2d at 870. \"Mere technical violations of the procedures prescribed by the Act do not constitute substantial failure to comply with its provisions.\" Id. (cleaned up). The criteria for differentiating between a substantial and technical error turns on the \"nature and extent of its effects[.]\" Id. The Court holds that Schulte cannot demonstrate a substantial failure to comply with the JSSA and that his statutory claims must therefore be rejected.11\n\nAs an initial matter, Schulte repleads his Sixth Amendment fair cross-section challenge under the JSSA. (Schulte Br. at 19.) But given that the Duren test governs fair cross-section challenges brought under both the Sixth Amendment and the JSSA, this claim must be dismissed for the reasons stated above. See supra 7–17.\n\nApart from his fair cross-section challenge, Schulte also contends that the following defects constitute substantial violations of the JSSA: (1) the Government's decision to seek the Indictment from White Plains and not Manhattan; (2) the exclusion of inactive voters from certain counties located in the White Plains array; (3) the allegedly erroneous proration of jurors\n\n11 To be sure, these arguments were already rejected by the Court under the systematic exclusion prong of the Sixth Amendment analysis. See supra 15–17. But because Schulte pleads these defects as separate violations of the JSSA, the Court conducts a separate analysis here.\n\n18\n\nDOJ-OGR-00002839",
  "text_blocks": [
    {
      "type": "printed",
      "content": "chance.\" (Schulte Br. at 17.) But the Court will not assume or infer that this District has been operating under an intentionally discriminatory Jury Plan since 2009. See Rioux, 97 F.3d at 659 (rejecting Equal Protection challenge due to lack of evidence showing intentional discrimination). Therefore, the Defendant's Equal Protection claim must be rejected.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "III. JSSA",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Schulte's remaining claims arise under the JSSA. To succeed on these claims, he must demonstrate a \"substantial failure to comply\" with the JSSA's provisions. LaChance, 788 F.2d at 870. \"Mere technical violations of the procedures prescribed by the Act do not constitute substantial failure to comply with its provisions.\" Id. (cleaned up). The criteria for differentiating between a substantial and technical error turns on the \"nature and extent of its effects[.]\" Id. The Court holds that Schulte cannot demonstrate a substantial failure to comply with the JSSA and that his statutory claims must therefore be rejected.11",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As an initial matter, Schulte repleads his Sixth Amendment fair cross-section challenge under the JSSA. (Schulte Br. at 19.) But given that the Duren test governs fair cross-section challenges brought under both the Sixth Amendment and the JSSA, this claim must be dismissed for the reasons stated above. See supra 7–17.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Apart from his fair cross-section challenge, Schulte also contends that the following defects constitute substantial violations of the JSSA: (1) the Government's decision to seek the Indictment from White Plains and not Manhattan; (2) the exclusion of inactive voters from certain counties located in the White Plains array; (3) the allegedly erroneous proration of jurors",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "11 To be sure, these arguments were already rejected by the Court under the systematic exclusion prong of the Sixth Amendment analysis. See supra 15–17. But because Schulte pleads these defects as separate violations of the JSSA, the Court conducts a separate analysis here.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "18",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002839",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Schulte"
    ],
    "organizations": [
      "Court",
      "Government"
    ],
    "locations": [
      "White Plains",
      "Manhattan"
    ],
    "dates": [
      "2009",
      "03/22/21"
    ],
    "reference_numbers": [
      "Case 1:17-cr-00383-PAC Document 1859",
      "DOJ-OGR-00002839"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with some citations and references to other documents. There are no visible stamps or handwritten annotations."
}