{
  "document_metadata": {
    "page_number": "6",
    "document_number": "614",
    "date": "02/24/22",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 614 Filed 02/24/22 Page 6 of 12\n\nII. JUROR 50'S PRESS STATEMENTS REVEAL THAT HE WAS BIASED AND SHOULD HAVE BEEN STRUCK FOR CAUSE\n\nWhere a juror's inaccurate answer during voir dire is revealed, the starting point for analyzing whether a new trial is required is the Supreme Court's decision in McDonough. The Court's plurality opinion states: \"[w]e hold that to obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.\" 464 U.S. at 556. However, the plurality's focus on whether the juror was \"honest\" does not mean that an inaccurate answer, though not given deliberately, cannot suffice to undermine the integrity of the verdict. Five Justices of the Court, in two concurring opinions, agreed that a court may vacate a conviction based upon a juror's erroneous answer if, under all the circumstances, the juror is shown to have been biased. See id. at 556 (explaining that a court can order a new trial \"regardless of whether a juror's answer is honest or dishonest\") (Blackmun, J., concurring with Stevens and O'Connor, JJ.); id. at 557-59 (incorrect answer may be sufficient) (Brennan, J., concurring with Marshall, J.).6\n\nThe Second Circuit has framed the test: \"a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause.\" United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006). \"False\" in this context means inaccurate or materially misleading, not necessarily deliberately untruthful; any other rule would unacceptably dilute the\n\n6 The rule that error need not be deliberate is followed in other contexts in criminal law. Cf. Strickler v. Greene, 527 U.S. 263, 288 (1999) (\"[U]nder Brady an inadvertent nondisclosure has the same impact on the fairness of the proceedings as deliberate concealment. 'If the suppression of evidence results in constitutional error, it is because of the character of the evidence, not the character of the prosecutor.'\") (internal citation omitted).\n\n5\n\nDOJ-OGR-00009113",
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      "content": "Case 1:20-cr-00330-PAE Document 614 Filed 02/24/22 Page 6 of 12",
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    {
      "type": "printed",
      "content": "II. JUROR 50'S PRESS STATEMENTS REVEAL THAT HE WAS BIASED AND SHOULD HAVE BEEN STRUCK FOR CAUSE",
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    {
      "type": "printed",
      "content": "Where a juror's inaccurate answer during voir dire is revealed, the starting point for analyzing whether a new trial is required is the Supreme Court's decision in McDonough. The Court's plurality opinion states: \"[w]e hold that to obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.\" 464 U.S. at 556. However, the plurality's focus on whether the juror was \"honest\" does not mean that an inaccurate answer, though not given deliberately, cannot suffice to undermine the integrity of the verdict. Five Justices of the Court, in two concurring opinions, agreed that a court may vacate a conviction based upon a juror's erroneous answer if, under all the circumstances, the juror is shown to have been biased. See id. at 556 (explaining that a court can order a new trial \"regardless of whether a juror's answer is honest or dishonest\") (Blackmun, J., concurring with Stevens and O'Connor, JJ.); id. at 557-59 (incorrect answer may be sufficient) (Brennan, J., concurring with Marshall, J.).6",
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    {
      "type": "printed",
      "content": "The Second Circuit has framed the test: \"a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause.\" United States v. Stewart, 433 F.3d 273, 303 (2d Cir. 2006). \"False\" in this context means inaccurate or materially misleading, not necessarily deliberately untruthful; any other rule would unacceptably dilute the",
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    },
    {
      "type": "printed",
      "content": "6 The rule that error need not be deliberate is followed in other contexts in criminal law. Cf. Strickler v. Greene, 527 U.S. 263, 288 (1999) (\"[U]nder Brady an inadvertent nondisclosure has the same impact on the fairness of the proceedings as deliberate concealment. 'If the suppression of evidence results in constitutional error, it is because of the character of the evidence, not the character of the prosecutor.'\") (internal citation omitted).",
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      "content": "5",
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      "content": "DOJ-OGR-00009113",
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  ],
  "entities": {
    "people": [
      "Blackmun, J.",
      "Stevens",
      "O'Connor, JJ.",
      "Brennan, J.",
      "Marshall, J."
    ],
    "organizations": [
      "Supreme Court",
      "Second Circuit"
    ],
    "locations": [],
    "dates": [
      "02/24/22",
      "1999"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 614",
      "464 U.S. at 556",
      "433 F.3d 273, 303 (2d Cir. 2006)",
      "527 U.S. 263, 288 (1999)",
      "DOJ-OGR-00009113"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and the text is clear."
}