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  "full_text": "Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 13 of 49\n\noriginal). \"The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would be a manifest injustice.\" Ferguson, 246 F.3d at 134.\n\nCourts strongly disfavor post-verdict inquiries into juror conduct. As the Supreme Court explained: \"Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first time . . . after the verdict, seriously disrupt the finality of the process. Moreover, full and frank discussion in the jury room, jurors' willingness to return an unpopular verdict, and the community's trust in a system that relies on the decisions of laypeople would all be undermined by a barrage of post-verdict scrutiny of juror conduct.\" Tanner v. United States, 483 U.S. 107, 120-21 (1987) (citations omitted). The Second Circuit has cautioned that \"post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts.\" Ianniello, 866 F.2d at 543.\n\nA defendant seeking Rule 33 relief based on alleged juror misrepresentations during voir dire must satisfy a two-part test: \"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.\" McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). The Second Circuit has held that these two requirements are conjunctive: \"in order to obtain a new trial, a defendant must show both that a juror gave a dishonest answer, and that the correct answer would have provided a basis for the defendant to challenge the juror for cause.\" Shaoul, 41 F.3d at 816 (emphasis in original). The first prong requires a deliberate misconduct, not an honest mistake. See id.; see also Part II.B.1.a, infra. The second prong requires the Court to determine whether, if the juror had answered truthfully, it would have granted a hypothetical strike for cause. See United States v. Stewart, 433 F.3d 273, 304 (2d\n\n11\n\nDOJ-OGR-00009811",
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      "type": "printed",
      "content": "original). \"The ultimate test on a Rule 33 motion is whether letting a guilty verdict stand would be a manifest injustice.\" Ferguson, 246 F.3d at 134.\n\nCourts strongly disfavor post-verdict inquiries into juror conduct. As the Supreme Court explained: \"Allegations of juror misconduct, incompetency, or inattentiveness, raised for the first time . . . after the verdict, seriously disrupt the finality of the process. Moreover, full and frank discussion in the jury room, jurors' willingness to return an unpopular verdict, and the community's trust in a system that relies on the decisions of laypeople would all be undermined by a barrage of post-verdict scrutiny of juror conduct.\" Tanner v. United States, 483 U.S. 107, 120-21 (1987) (citations omitted). The Second Circuit has cautioned that \"post-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts.\" Ianniello, 866 F.2d at 543.\n\nA defendant seeking Rule 33 relief based on alleged juror misrepresentations during voir dire must satisfy a two-part test: \"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.\" McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548, 556 (1984). The Second Circuit has held that these two requirements are conjunctive: \"in order to obtain a new trial, a defendant must show both that a juror gave a dishonest answer, and that the correct answer would have provided a basis for the defendant to challenge the juror for cause.\" Shaoul, 41 F.3d at 816 (emphasis in original). The first prong requires a deliberate misconduct, not an honest mistake. See id.; see also Part II.B.1.a, infra. The second prong requires the Court to determine whether, if the juror had answered truthfully, it would have granted a hypothetical strike for cause. See United States v. Stewart, 433 F.3d 273, 304 (2d",
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    "dates": [
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      "1987",
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      "Case 1:20-cr-00330-PAE",
      "Document 643",
      "DOJ-OGR-00009811"
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  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}