United States v. DeJean, 988 F.3d 813

Patrick Dejean, a Jefferson Parish justice of the peace (since 2009), was indicted for diverting court funds, obtaining bank loans in the court’s name, and using the money for casino gambling.
At a 2019 federal trial, Dejean was convicted of 13 counts of mail fraud and 3 counts of making false statements to a bank; acquitted on two wire-fraud counts.
During voir dire the court granted for-cause strikes to two jurors who expressed strong anti-gambling views (Jurors 22 and 27). Juror 31 said she does not gamble, called it "silly," acknowledged family gambling problems, said gambling "possibly" could affect her judgment, and—after defense questioning—stated she "shouldn’t sit on this case."
Defense counsel moved to strike Juror 31 for cause twice; the district court denied both requests, finding her responses reflected demeanor and a desire to end questioning rather than disqualifying bias. Defense did not use a peremptory strike on Juror 31 and exhausted other peremptories.
Dejean moved for a new trial alleging juror bias; the district court denied the motion. Dejean appealed, arguing the denial of a for-cause strike for Juror 31 deprived him of an impartial jury.

Issue	Plaintiff's Argument (United States)	Defendant's Argument (Dejean)	Held
Whether the district court abused its discretion by refusing to remove for cause Juror 31 for anti-gambling bias	The court properly evaluated Juror 31’s testimony, demeanor, and prior statement she could follow instructions; no actual prejudice shown, so no abuse of discretion	Juror 31 admitted her views on gambling could "possibly" affect her and said she "shouldn’t sit on this case," demonstrating actual prejudice that required removal	Affirmed: district court’s denial of a for-cause strike was not an abuse of discretion; juror impartiality finding entitled to great deference

Skilling v. United States, 561 U.S. 358 (2010) (trial-court determinations of juror impartiality receive heightened deference)
United States v. Hinojosa, 958 F.2d 624 (5th Cir. 1992) (deference to district court on juror bias findings)
Celestine v. Blackburn, 750 F.2d 353 (5th Cir. 1984) (voir dire breadth and bias assessment upheld)
United States v. Apodaca, 666 F.2d 89 (5th Cir. 1982) (standard for actual prejudice and scope of voir dire)
Virgil v. Dretke, 446 F.3d 598 (5th Cir. 2006) (distinguishing unequivocal juror statements of inability to be impartial)
United States v. Martinez-Salazar, 528 U.S. 304 (2000) (juror statements denying presumption of innocence require removal)
Wicker v. McCotter, 783 F.2d 487 (5th Cir. 1986) (trial judge’s demeanor-based credibility assessments in juror bias determinations)