United States v. Snipes
2010 U.S. Dist. LEXIS 123180
| M.D. Fla. | 2010Background
- Snipes was convicted by jury of three counts of willful failure to file income tax returns for 1999–2001; acquitted of other charged offenses.
- Sentencing on May 1, 2008 imposed consecutive terms totaling three years; appellate court affirmed conviction and sentence in 2010.
- After the Court of Appeals decision, Snipes filed motions to interview jurors and for a new trial based on juror misconduct and Brady/Giglio concerns.
- Emails from jurors alleged pre-deliberation guilt beliefs; Rule 606(b) and Local Rule 5.01(d) govern post-verdict juror interviews.
- Court denied the juror-interview motions and the Brady/Giglio-based new-trial motion and ordered enforcement of the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether juror interviews are permitted. | Snipes contends juror misconduct warrants interviews and a new trial. | United States argues Rule 606(b) bars such interviews and there is no extrinsic influence. | Denied; Rule 606(b) precludes interviews and no outside influence shown. |
| Whether the Brady/Giglio claim entitles a new trial. | Snipes asserts suppressed Brady/Giglio impeachment material about Starr mandates relief. | United States contends no suppression, no material prejudice, and no fishing expedition warranted. | Denied; no credible Brady/Giglio violation established. |
| Whether the judgment should be enforced and bail issues resolved. | Snipes challenges ongoing enforcement and requests bail-related relief pending appeal. | United States moves to enforce judgment; requests denial of further delay. | Judgment enforced; bail motions denied or denied as moot per Bail Reform Act considerations. |
Key Cases Cited
- Tanner v. United States, 483 U.S. 107 (U.S. 1987) (post-verdict juror scrutiny must be limited to protect deliberations)
- McDonald v. Pless, 238 U.S. 264 (U.S. 1915) (privacy of jury deliberations; risks of public scrutiny)
- United States v. Siegelman, 561 F.3d 1215 (11th Cir. 2009) (Rule 606(b) governs juror testimony and extraneous information)
- United States v. Venske, 296 F.3d 1284 (11th Cir. 2002) (post-verdict juror interviews limited to extraneous influence)
- Washington v. Strickland, 673 F.2d 879 (11th Cir. 1982) (limits on probing jurors' mental processes after verdict)
- United States v. Griek, 920 F.2d 840 (11th Cir. 1991) (finality and integrity of the jury system)
- United States v. Benally, 546 F.3d 1230 (10th Cir. 2008) (illustrates the protective role of Rule 606(b))