{
  "document_metadata": {
    "page_number": "16",
    "document_number": "Case 4:20-cr-00354-PAE Document 1359 Filed 03/22/21 Page 16 of 20",
    "date": "03/22/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "proceeded this way was because of an external force: the COVID-19 pandemic and its substantial curtailment of in-person proceedings throughout the District. Rioux, 97 F.3d at 658. This allegation therefore does not establish systematic exclusion. Second, Schulte argues that the Jury Plan's replenishment of the master wheels only once every four years constitutes systematic exclusion. (Schulte Br. at 14.) According to Schulte, the four-year period causes addresses to grow \"stale\" as people move to new residences, and because African Americans and Hispanic Americans are, on average, younger and thus more likely to move, he argues that these groups are systematically excluded. (See id. 14-15.) But even granting the dubious premises that make up this deductive reasoning, the Court remains unpersuaded because, again, the true cause of the exclusion—younger people moving more often—is an external force, not a systematic defect inherent in the Jury Plan. Rioux, 97 F.3d at 658 (concluding that a jury system that led to undeliverable questionnaires did not constitute systematic exclusion). At bottom, the Court cannot charge the District's Jury Plan with a Sixth Amendment violation because of how often people move residences throughout the District. Third, Schulte asserts that the Jury Plan's exclusive reliance on voter registration lists constitutes systematic exclusion. This claim, however, is foreclosed by the Second Circuit's decision in Schanbarger. See 77 F.3d at 1424 (\"[A] jury venire drawn from voter registration lists violates neither the Sixth Amendment's fair cross-section requirement nor the Fifth Amendment's guarantee of Equal protection.\"). Finally, Schulte alleges that the exclusion of \"inactive voters\" in certain counties within White Plains constitutes systematic exclusion because African Americans and Hispanic Americans are more likely to be inactive voters. (Schulte Br. at 15.) But again, the cause of the",
  "text_blocks": [
    {
      "type": "printed",
      "content": "proceeded this way was because of an external force: the COVID-19 pandemic and its substantial curtailment of in-person proceedings throughout the District. Rioux, 97 F.3d at 658. This allegation therefore does not establish systematic exclusion.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Second, Schulte argues that the Jury Plan's replenishment of the master wheels only once every four years constitutes systematic exclusion. (Schulte Br. at 14.) According to Schulte, the four-year period causes addresses to grow \"stale\" as people move to new residences, and because African Americans and Hispanic Americans are, on average, younger and thus more likely to move, he argues that these groups are systematically excluded. (See id. 14-15.) But even granting the dubious premises that make up this deductive reasoning, the Court remains unpersuaded because, again, the true cause of the exclusion—younger people moving more often—is an external force, not a systematic defect inherent in the Jury Plan. Rioux, 97 F.3d at 658 (concluding that a jury system that led to undeliverable questionnaires did not constitute systematic exclusion). At bottom, the Court cannot charge the District's Jury Plan with a Sixth Amendment violation because of how often people move residences throughout the District.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, Schulte asserts that the Jury Plan's exclusive reliance on voter registration lists constitutes systematic exclusion. This claim, however, is foreclosed by the Second Circuit's decision in Schanbarger. See 77 F.3d at 1424 (\"[A] jury venire drawn from voter registration lists violates neither the Sixth Amendment's fair cross-section requirement nor the Fifth Amendment's guarantee of Equal protection.\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, Schulte alleges that the exclusion of \"inactive voters\" in certain counties within White Plains constitutes systematic exclusion because African Americans and Hispanic Americans are more likely to be inactive voters. (Schulte Br. at 15.) But again, the cause of the",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "16",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002837",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Schulte"
    ],
    "organizations": [
      "District",
      "Second Circuit",
      "Court"
    ],
    "locations": [
      "White Plains",
      "District"
    ],
    "dates": [
      "03/22/2021"
    ],
    "reference_numbers": [
      "Case 4:20-cr-00354-PAE Document 1359",
      "Rioux, 97 F.3d at 658",
      "Schanbarger, 77 F.3d at 1424",
      "DOJ-OGR-00002837"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the Jury Plan and allegations of systematic exclusion. The text is printed and there are no visible stamps or handwritten notes. The document is page 16 of 20."
}