Saturday, November 2, 2013

United States v. Thomas case brief

United States v. Thomas case brief summary
116 F.3d 606 (1997)

CASE SYNOPSIS
Defendants challenged the decision of the United States District Court for the Northern District of New York, convicting defendants on federal narcotics charges involving conspiracy to possess and distribute cocaine and crack cocaine and actual possession and distribution of the substances. After a mistrial was declared, a second trial was held in which defendants were found guilty by the trial jury.

CASE FACTS
Ten defendants were charged with conspiracy to possess and distribute cocaine and crack cocaine, and actual possession and distribution of the substances. A superseding indictment added forfeiture counts against defendants. After a government witness made prejudicial statements on the stand, a mistrial was declared. A second trial of the same defendants began two days later and the jury returned verdicts of guilty for all defendants, who were thus convicted of related conduct involving violations of federal narcotics laws. Defendants argued that the trial court abused its discretion when it ordered the dismissal of one of the jurors during the course of jury deliberations. The trial court had based its decision to remove the juror on a finding that the juror was purposefully disregarding the court's instructions on the law because the juror intended to acquit defendants regardless of the evidence of their guilt.

DISCUSSION
The appellate court vacated the judgments and remanded for a new trial, finding that the trial court erred in dismissing the juror under Fed. R. Crim. P. 23(b) because the juror may have been following the court's instructions, but was unpersuaded by prosecution's case.

CONCLUSION

The appellate court vacated the judgments as to defendants' convictions on federal narcotics charges involving conspiracy to possess and distribute cocaine and crack cocaine and actual possession and distribution of the substances, and remanded the case for a new trial because a juror was improperly dismissed by trial court. Evidence revealed the juror's view on the merits of the case may have been motivated by doubts about defendants' guilt.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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