No. 23-416

Derek Michael Chauvin v. Minnesota

Lower Court: Minnesota
Docketed: 2023-10-19
Status: Denied
Type: Paid
Amici (1)Response Waived
Tags: change-of-venue community-bias community-harm criminal-procedure juror-bias juror-prejudice presumed-prejudice sixth-amendment venue-change voir-dire
Key Terms:
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Latest Conference: 2023-11-17
Question Presented (AI Summary)

Whether community harm and threat of harm is a presumed community bias and must be considered as a singular inquiry as an extreme case creating circumstances so inherently prejudicial that jury bias must also be presumed because jurors have a vested interest in the outcome of the case, thereby narrowing a trial court's discretion and mandating a change of venue, without voir dire, to ensure a constitutionally fair trial under the Sixth Amendment

Question Presented (OCR Extract)

QUESTIONS PRESENTED Although a slightly similar question was presented to this Court in Skilling v. ULS., 558 U.S. 945 (2009), questions remained unresolved regarding the presumption of presumed prejudice and the meaning of an “extreme case.” While Skilling identified four non-exclusive factors to presume prejudice and warrant a change of venue, issues related to community harm and juror vested interests as presumptive bias factors prior to voir dire were not addressed. A community from which the jurors will be chosen experienced catastrophic violent riots resulting from a police officer’s acts and believed that further rioting or harm to them or their families will result if they acquit the police officer as a criminal defendant. The defendant’s motion for a change of venue was denied. The questions presented are: 1. Whether community harm and threat of harm is a presumed community bias and must be considered as a singular inquiry as an extreme case creating circumstances so inherently prejudicial that jury bias must also be presumed because jurors have a vested interest in the outcome of the case, thereby narrowing a trial court’s discretion and mandating a change of venue, without voir dire, to ensure a constitutionally fair trial under the Sixth Amendment. ii QUESTIONS PRESENTED—Continued 2. Whether when evidence of juror prejudice and voir dire misconduct found after trial indicates a juror stereotyped, prejudged, or carried an undisclosed animus against the criminal defendant, the Sixth Amendment requires the trial court to consider that evidence and any resulting denial of the right to trial by an impartial jury.

Docket Entries

2023-11-20
Petition DENIED.
2023-11-16
Brief amicus curiae of Minnesota Police and Peace Officers Association filed.
2023-11-01
DISTRIBUTED for Conference of 11/17/2023.
2023-10-27
Waiver of right of respondent Minnesota to respond filed.
2023-10-16

Attorneys

Derek Chauvin
William F. MohrmanMohrman & Kaardal, P.A., Petitioner
William F. MohrmanMohrman & Kaardal, P.A., Petitioner
Minnesota
Neal Kumar KatyalHogan Lovells US LLP, Respondent
Neal Kumar KatyalHogan Lovells US LLP, Respondent
Minnesota Police and Peace Officers Association
Christopher W. Madel — Amicus
Christopher W. Madel — Amicus