Jury Misconduct

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7^th Circuit Court of Appeals

Case Name: United States of America v. Luis Garcia

Case No.: 21-2434

Officials: Wood, St. Eve, and Jackson-Akiwumi, Circuit Judges.

Focus: Jury Misconduct

Garcia provided logistical assistance while another individual unloaded items from a concealed compartment on an empty bus, with these items being controlled substances. As a result of his involvement in this incident, Garcia was found guilty of possessing controlled substances with the intention to distribute and conspiring to commit the same offense. His defense, which contended that while he might have been aware of the bus containing unspecified illicit items, the prosecution failed to establish his knowledge of the specific presence of drugs, was rejected by the court. Furthermore, Garcia pointed out that notes submitted by jurors to the court during the trial suggested that they were deliberating prematurely and potentially not adhering to the court’s instructions.

The Seventh Circuit upheld the decision. When the evidence was considered in a manner most favorable to the government’s case, it demonstrated that Garcia was aware that the bus contained controlled substances. Moreover, Garcia was cognizant that the focus of the conspiracy was centered on drugs, rather than a more generalized illicit objective. The court underscored conversations where Garcia discussed the need for additional time due to difficulties in removing the drugs and another dialogue where he explicitly mentioned drugs. While the notes from the jurors hinted at some irregularities in the jury proceedings, the district court’s determination that these did not constitute misconduct was not deemed an abuse of discretion. Courts typically assume that jurors adhere to the instruction not to deliberate prematurely, and in this case, there was no “overwhelming” evidence to counteract this presumption.

Affirmed.

Decided 08/24/23

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