Law School Case Brief
United States v. McClinton - 135 F.3d 1178 (7th Cir. 1998)
U.S. Const. amends. V and VI protect a criminal defendant from a jury's lynch mob mentality through the guarantees of due process of law and trial by an impartial jury. U.S. Const. amends. V, VI. "Impartiality" is not a technical conception. It is a state of mind. The test for determining impartiality in a prospective juror is whether he can lay aside his impression or opinion and render a verdict based on the evidence presented in court. Due process, however, does not require a new trial every time a juror has been placed in a potentially compromising situation. Rather, due process consists of a jury able to decide the case solely on the evidence before it and a trial judge ever watchful to prevent prejudicial occurrences and to determine the effect of such occurrences when they happen.
At trial before the district court, a jury found defendants to be guilty of conspiracy and various drug-related crimes, as part of a drug-trafficking conspiracy. The district court entered a guidelines sentence for each defendant based upon his level of participation. Three defendants appealed from their convictions for drug crimes and conspiracy as well as their sentences. Defendants challenged the use of voir dire as an insufficient means of purging the remaining jurors of racially biased statements expressed by another juror. They also argued that the court abused its discretion by allowing a biased juror to remain on the panel.
Was there reversible error in the conviction of the defendants?
The court reviewed each argument raised by each defendant and found no error. The court determined that the district court properly limited any prejudicial impact of the improper statements by a prosecutor through jury instructions and other means. The court ruled that the district court responded properly to allegations of jury misconduct during the trial by conducting voir dire and dismissing one juror. The court also found no clear error in the calculation of defendants' sentences. Therefore, the court affirmed defendants' convictions and sentences.
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