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Document 20-00630

AI Analysis

Summary: The document discusses Maxwell's appeal of the District Court's denial of her motion for a new trial, arguing that Juror 50's failure to accurately respond to questions about his history of sexual abuse during jury selection compromised her right to a fair and impartial jury. The appellate court reviews the District Court's decision for 'abuse of discretion' and defers to its judgment, citing the high standard for granting a new trial. The court ultimately upholds the District Court's denial of Maxwell's motion.
Significance: This document is potentially important because it reveals the appellate court's reasoning in upholding the District Court's denial of Maxwell's motion for a new trial, and provides insight into the court's standards for evaluating juror bias and the 'abuse of discretion' standard.
Key Topics: Motion for a new trial Jury selection and juror bias District Court's discretion in denying a new trial
Key People:
  • Maxwell - Defendant in the criminal case
  • Juror 50 - Juror whose responses during jury selection are at issue
Document Type
Court Filing
Date
Unknown
Pages
1
Folder
IMAGES006

Full Text

Case 1:20-cr-00630-PAE Document 178 Filed 03/27/22 Page 126 of 261 3. The District Court Did Not Abuse Its Discretion in Denying Maxwell's Motion for a New Trial Maxwell contends that she was deprived of her constitutional right to a fair and impartial jury because Juror 50 failed to accurately respond to several questions related to his history of sexual abuse as part of the jury questionnaire during jury selection. Following a special evidentiary hearing, the District Court denied Maxwell's motion for a new trial. We review a District Court's denial of a motion for a new trial for abuse of discretion.27 We have been extremely reluctant to "haul jurors in after they have reached a verdict in order to probe for potential instances of bias, misconduct or extraneous influences."28 While courts can "vacate any judgment and grant a new trial if the interest of justice so requires," Fed. R. Crim. P. 33(a), they should do so "sparingly" and only in "the most extraordinary circumstances."29 A district court "has 27 See Rivas v. Brattesani, 94 F.3d 802, 807 (2d Cir. 1996). "[W]e are mindful that a judge has not abused her discretion simply because she has made a different decision than we would have made in the first instance." United States v. Ferguson, 246 F.3d 129, 133 (2d Cir. 2001). We have repeatedly explained that the term of art "abuse of discretion" includes errors of law, a clearly erroneous assessment of the evidence, or "a decision that cannot be located within the range of permissible decisions." In re Sims, 534 F.3d 117, 132 (2d Cir. 2008) (citation and internal quotation marks omitted). 28 United States v. Moon, 718 F.2d 1210, 1234 (2d Cir. 1983). 29 Ferguson, 246 F.3d at 134. 17 DOJ-OGR-00014867