Sampson v. United States

SELYA, Circuit Judge.

New accouterments of our criminal justice system are either more fundamental or more precious than the accused’s right to an impartial jury. That right is threatened when — as in this case — juror dishonesty occurs during the voir dire process yet is not discovered until well after final judgment has entered on the jury’s verdict. But finality is also valuable, and not every instance of juror dishonesty requires setting aside a previously rendered verdict.

In its present posture, this case poses important questions about when and under what circumstances the belated…