United States v. Sampson
2011 WL 5022335
D. Mass.2011Background
- Gary Sampson was charged with two carjackings resulting in death and sought the death penalty under the Federal Death Penalty Act.
- Sampson pled guilty but a jury trial was required to determine whether death was justified, per Supreme Court and FDPA standards.
- A capital jury was seated after extensive voir dire; juror C, among others, provided dishonest answers about personal experiences during voir dire.
- Post-trial § 2255 motion claimed violations of impartial jury rights due to juror dishonesty; three evidentiary hearings were held.
- The court vacated Sampson’s death sentence and ordered a new sentencing trial based on McDonough-type analysis of dishonest voir dire answers.
- The ruling emphasizes that McDonough provides an alternative path to relief beyond actual or implied bias, focusing on truthful voir dire and potential disruption to impartiality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McDonough provides relief despite lack of actual/implicit bias | Sampson asserts McDonough grounds for a new sentencing trial due to dishonest voir dire. | U.S. contends McDonough does not require bias to grant relief; other avenues exist. | Yes; McDonough relief applies and favors Sampson. |
| Whether juror C was actually biased | C’s dishonesty and traumatic experiences imply bias affecting impartiality. | No clear evidence of actual bias; demeanor inconclusive. | Not proven; actual bias not established. |
| Whether juror C was impliedly biased | Repeated dishonesty and emotionally charged experiences related to trial issues imply bias. | No direct relationship or sufficiently close similarity to mandate implied bias. | Not proven; implied bias not established. |
| Whether juror C could have been excused for cause (inferable bias) given information after voir dire | Knowledge of C’s psychological distress and related events would have supported a cause dismissal. | Inferable bias exists in some contexts, but not clearly here. | The court found McDonough prong five satisfied; cause dismissal would have been permissible. |
| Whether juror D or G’s inaccurate answers warrant relief under McDonough | Dishonest or inaccurate answers could undermine impartiality. | Inaccuracies were not dishonesty and did not implicate impartiality. | McDonough relief not granted for D or G. |
Key Cases Cited
- McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548 (1984) (establishesMcDonough test for new trial based on dishonest voir dire answers)
- Woodson v. North Carolina, 428 U.S. 280 (1976) (death penalty reliability and capital sentencing concerns)
- Jones v. United States, 527 U.S. 373 (1999) (death penalty requires each juror to be able to decide solely on the evidence)
- Morgan v. Illinois, 504 U.S. 719 (1992) (due process concerns in juror impartiality affecting death penalty)
- United States v. Martinez-Salazar, 528 U.S. 304 (2000) (one juror's impartiality can defeat death sentence; jury must be impartial)
- Amirault v. Fair, 968 F.2d 1404 (1st Cir. 1992) (recognizes McDonough as one of three potential relief paths; separate bias theories exist)
- Dall v. United States, 970 F.2d 964 (1st Cir. 1992) (discusses McDonough and non-disclosure vs inaccurate answers; relief paths)
- Torres v. United States, 128 F.3d 38 (2d Cir. 1997) (introduces inferable bias as a category for cause)
- Greer v. United States, 285 F.3d 171 (2d Cir. 2002) (discusses whether correct voir dire responses would have justified cause)
- Langford v. Langford, 990 F.2d 65 (2d Cir. 1993) (example of dishonesty in voir dire under similar factual tension)