Background
Attila Colar was convicted on forty-four federal counts involving alleged Paycheck Protection Program fraud and obstruction. Colar argued law enforcement targeted him based on race and religion. An alternate juror expressed bias against this defense theory after voir dire.
The court’s reasoning
The Sixth Amendment guarantees criminal defendants the right to trial by an impartial jury. The participation of even a single biased juror in rendering a guilty verdict is structural error requiring reversal. Once a colorable issue of juror bias arises, the court must investigate before the juror continues to serve.
The participation of even a single biased juror in rendering a guilty verdict is structural error requiring reversal.
What it means going forward
New trial ordered for defendant due to Sixth Amendment violation.