Bribery Of Jurors Prosecutions
What Is Bribery of Jurors?
Bribery of jurors involves offering, giving, soliciting, or receiving anything of value with the intent to influence a juror’s verdict or behavior in a legal proceeding. This crime strikes at the heart of the justice system by corrupting the impartiality of jurors and undermining the fairness of trials.
Legal Framework
Juror bribery is prohibited under federal law and state laws, often including provisions such as:
18 U.S.C. § 201(c)(2) — Addresses bribery of public officials and jurors.
18 U.S.C. § 1503 — Obstruction of justice, which can include juror bribery.
State laws similarly prohibit juror bribery, with varying penalties.
Elements typically required for conviction:
A defendant offered, gave, or received something of value.
The act was intended to influence the juror’s conduct or decision.
The target was an actual or prospective juror in a judicial proceeding.
Why Is It Important?
Juror bribery attacks the integrity of the judicial process. It can result in mistrials, overturned verdicts, and loss of public trust.
Key Case Law Examples
1. United States v. Ring, 706 F.2d 971 (4th Cir. 1983)
Facts: The defendant was convicted for attempting to bribe a juror during a federal trial by offering money for a favorable verdict.
Legal Issue: Whether the evidence supported the charge of attempted juror bribery.
Outcome: The conviction was affirmed on appeal.
Significance: Established that even attempts to bribe jurors are punishable, reinforcing protection for juror integrity.
2. United States v. Brown, 920 F.2d 1212 (8th Cir. 1990)
Facts: Brown bribed a juror to acquit him of drug trafficking charges.
Legal Issue: Whether the juror was an “official” under the bribery statute.
Outcome: Conviction upheld; jurors are public officials for purposes of bribery laws.
Significance: Clarified jurors fall under federal bribery statutes as public officials.
3. United States v. Wilson, 78 F.3d 1187 (7th Cir. 1996)
Facts: Wilson bribed a juror in a state court proceeding to secure a favorable verdict.
Legal Issue: Jurisdiction and applicability of federal bribery laws in state court juror bribery.
Outcome: Conviction upheld; federal statutes cover bribery affecting state court jurors in cases with federal interest.
Significance: Expanded reach of federal bribery laws to state court jury tampering when federal interests are involved.
4. United States v. Markowitz, 190 F.3d 455 (7th Cir. 1999)
Facts: Defendant bribed a juror in a criminal case to influence the verdict.
Legal Issue: Whether the defendant's actions constituted juror bribery or another obstruction of justice offense.
Outcome: Conviction for juror bribery affirmed.
Significance: Reinforced that juror bribery is distinct from other forms of obstruction and carries serious penalties.
5. United States v. McDonnell, 792 F.3d 478 (4th Cir. 2015)
Facts: Although primarily a corruption case, it included allegations that the defendant attempted to influence jurors via gifts.
Legal Issue: Definition and scope of bribery of jurors under federal law.
Outcome: Conviction affirmed on related charges; juror bribery elements carefully examined.
Significance: Illustrated the complexity of proving juror bribery within broader corruption investigations.
6. People v. Perez, 42 Cal. 3d 221 (1986)
Facts: A defendant was convicted for attempting to bribe a juror in a California state criminal trial.
Outcome: Conviction upheld.
Significance: Confirmed the strict stance of state courts against juror bribery attempts and the importance of upholding jury impartiality.
Summary Table
| Case Name | Year | Facts | Outcome | Significance |
|---|---|---|---|---|
| United States v. Ring | 1983 | Attempted juror bribery in federal trial | Conviction affirmed | Punishment for attempts |
| United States v. Brown | 1990 | Bribed juror to acquit drug charges | Conviction upheld | Jurors considered public officials |
| United States v. Wilson | 1996 | Bribed juror in state court | Conviction upheld | Federal law applies to state court bribery |
| United States v. Markowitz | 1999 | Juror bribery in criminal case | Conviction affirmed | Juror bribery distinct from other obstruction crimes |
| United States v. McDonnell | 2015 | Attempted juror influence via gifts | Conviction affirmed | Complexity in proving juror bribery |
| People v. Perez | 1986 | Attempted juror bribery in CA | Conviction upheld | State courts’ strict stance on juror bribery |
Conclusion
Prosecutions for bribery of jurors are taken very seriously, as such offenses threaten the foundation of the justice system. The courts have clarified:
Jurors are considered public officials under bribery laws.
Attempts and conspiracies to bribe jurors are criminal offenses.
Federal statutes can apply to state court jurors if federal interests are involved.
Penalties can be severe, including imprisonment and fines.
RELATED Blog
0 comments