US v. Williamson: Williamson went to trial in the Southern District of West Virginia for drug and firearms charges. During voir dire, an eventually-seated juror explained that he had once been a police chief and, overall, a police officer for more than three decades. When the entire panel was asked if any of them had “ever been involved with any conflict, controversy, or litigation with any department or agency of the United States,” all answered “no.” Williamson was convicted on all counts and sentenced to 240 months in prison.
While his case was pending on appeal, Williamson learned that the juror had been part of “Team Mingo,” a group of Mingo County officials who were involved in various forms of corruption, including with drugs. While the juror was never charged as part of the Government’s investigation into Team Mingo, he was questioned and given a target letter. On remand, when asked why he didn’t explain all this during voir dire, the juror claimed that it had been long enough ago and hadn’t resulted in anything that he simply forgot. Williamson argued he was entitled to a new trial because the juror had lied to avoid disclosing an embarrassing part of his past. The district court agreed that the juror had lied, but concluded he had not been biased and denied the motion for a new trial.
On appeal, the Fourth Circuit affirmed the denial of Williamson’s motion for a new trial. Extending the required deference to the district court’s factual findings (including on the juror’s credibility regarding any bias), the court concluded there was no abuse of discretion in denying a new trial. Particularly, the court noted that the juror did not suggest he was biased either way due to his experience and that the district court’s factual finding on that matter was not clearly erroneous. Ultimately, the court concluded there had been no actual, implied, or inferred bias on the juror’s part.
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