Background
Andre Dewayne Williamson was convicted of distributing fentanyl and possessing a firearm in furtherance of a drug trafficking crime. During jury selection, a prospective juror disclosed his history as a police chief but failed to mention he was the target of a federal investigation into a corruption ring known as Team Mingo. After the trial, this information came to light, and Williamson moved for a new trial, arguing the juror’s concealment violated his right to an impartial jury.
The court’s reasoning
The court reviewed the denial of the new trial motion for abuse of discretion. It distinguished between actual bias, implied bias, and inferred bias. The court found no actual bias because the juror testified he was not biased and the district court credited his testimony. The court found no implied bias because the juror’s past connection to the government was not sufficiently close to the parties or the crime to mandate automatic disqualification. The court also rejected inferred bias as a per se rule of disqualification, noting that such a finding remains within the trial court’s discretion.
Like offensive linemen on a football team, standards of review lack glamour but are often decisively important.
Portillo Flores v. Garland, 3 F.4th 615, 649 n.11 (4th Cir. 2021)
What it means going forward
The decision reinforces the high bar for overturning jury verdicts based on juror misconduct, requiring proof of actual bias or a specific per se rule of disqualification rather than mere dishonesty.
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