United States v. Franchie Farmer, 717 F.3d 559

Farmer was convicted of armed bank robbery (Capaha Bank Tamms, IL, Nov. 6, 2008) and use of a firearm during a crime of violence.
The government’s case tied Farmer to planning the robbery, writing the demand note, and driving the getaway car with a disabled client.
Evidence included a witness identifying the robbers, fingerprints on the demand note, Farmer’s cell phone data showing calls with Wrice, and trial testimony from Wrice and Anderson under cooperation agreements.
A district judge denied Farmer’s motion for a new trial after an alternate juror reported pre-deliberation comments by jurors.
Farmer challenged sufficiency of the evidence on appeal and renewed the juror-misconduct claim; the district court’s rulings were reviewed for plain error on the sufficiency issue and for abuse of discretion on the new-trial motion.
The court affirmed the conviction and denied the new-trial motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to support guilt	Farmer (plaintiff) argues evidence is insufficient	Farmer argues credibility issues and isolated pieces undermine guilt	Sufficient evidence; standard met
Premature deliberations and juror bias and denial of new trial	Farmer alleges juror misconduct affected deliberations	District court properly denied new trial; no presumptive prejudice	No abuse of discretion; no presumption of prejudice; denial affirmed

Tavarez, 626 F.3d 902 (7th Cir. 2010) (sufficiency standard from Jackson v. Virginia applied on appeal)
Jackson v. Virginia, 443 U.S. 307 (Sup. Ct. 1979) (establishes ‘no rational trier of fact’ standard)
Durham, 645 F.3d 883 (7th Cir. 2011) (reiterates viewing evidence in light most favorable to the prosecution)
Huddleston, 593 F.3d 596 (7th Cir. 2010) (standard for evaluating sufficiency with multiple evidentiary pieces)
Jones, 713 F.3d 336 (7th Cir. 2013) (review of credibility determinations requires deference to jury)
Carraway, 612 F.3d 642 (7th Cir. 2010) (credibility challenges are difficult to overturn on appeal)
Morales, 655 F.3d 608 (7th Cir. 2011) (Rule 606(b) implications; prematurity of deliberations considered)
Tanner v. United States, 483 U.S. 107 (1987) (finality concerns; post-verdict juror inquiries discouraged)
Vasquez-Ruiz, 502 F.3d 700 (7th Cir. 2007) (juror-notebook communication; prejudice presumption analyzed)
Kimberlin, 805 F.2d 210 (7th Cir. 1986) (external influence not within Rule 606(b) limits; prejudice assessment allowed)
Paneras, 222 F.3d 406 (7th Cir. 2000) (evaluating prejudicial material independent of juror's stated effect)