United States v. Javier Amaya, 731 F.3d 761

Javier Amaya was convicted by jury of one count of conspiracy to launder money under 18 U.S.C. § 1956(a)(1)(B).
District court granted a new trial after finding plain error: the verdict form lacked a place to indicate a Step 1 verdict and the court substituted jury polling for a normal verdict return.
Evidence showed Javier and his co-conspirator Angel opened bank accounts to launder proceeds from drug activity and later paid a third party with those funds.
For Angel, the jury returned a verdict including money-laundering and drug-conspiracy findings; for Javier, Step 1 had no explicit verdict box but Step 2 identified an objective.
The district court conducted two in-court polls of jurors to confirm unanimous guilt of Javier after noting the form defect, raising concerns about coercion and fairness.
The government appealed, and the Eighth Circuit affirmed, holding the district court did not abuse its discretion and that the plain-error rulings were proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the verdict-form error and polling amounted to plain error justifying a new trial	Amaya argues plain error affected substantial rights and warranted a new trial.	Amaya contends the errors were minor and did not prejudice the defendant.	No abuse of discretion; plain-error found and new trial affirmed.
Whether polling the jury in open court coerced jurors or undermined their independence	Amaya asserts polling coerced jurors and undermined deliberations.	Amaya contends polling was improper and coercive.	Polling did not coercively affect jurors and was not error requiring reversal.
Whether the verdict-form omission, considered with overall jury instructions, invalidated the verdict	Amaya claims error in Step 1 lacking verdict box undermined the verdict.	Amaya argues overall instructions still properly charged the jury.	The record shows proper understanding and unanimous verdict; no reversible error.

United States v. McBride, 862 F.2d 1316 (8th Cir. 1988) (rule for plain-error review in new-trial motions)
Brasfield v. United States, 272 U.S. 448 (Supreme Court 1926) (polling juries after verdict can be coercive; warns against deadlocked-jury polling)
Amos v. United States, 496 F.2d 1269 (8th Cir. 1974) (approval of polling to dispel confusion in verdicts; consideration of jury independence)
Poitra, 648 F.3d 884 (8th Cir. 2011) (plain-error framework for new-trial relief in criminal cases)
Cundiff v. United States, 501 F.2d 188 (8th Cir. 1974) (verdict-form issues tied to in-court explanations and jury questions; distinction from deadlock polling)