United States v. Ricardo Mitchell

OPINION

(August 7, 2012)

Chagares, Circuit Judge

Ricardo Mitchell appeals his conviction on charges related to his possession of a firearm with an obliterated serial number. We consider whether the “close cousin” of the prosecutor and an employee of the police department who worked with Government witnesses should have been disqualified as jurors in Mitchell’s trial pursuant to the doctrine of implied bias. The law, we conclude, presumes bias in jurors who are close relatives of the parties in a case. Because the District Court did not elicit sufficient information on the nature of the…