Clark v. United States
1933 U.S. LEXIS 161, 53 S. Ct. 465, 289 U.S. 1 (1933)
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Rule of Law:
A juror who deliberately conceals information or provides false answers during voir dire examination to secure a position on the jury with the intent to obstruct justice is guilty of criminal contempt. The privilege of secrecy for jury deliberations does not apply when the juror's relationship with the court was secured through fraud.
Facts:
- Genevieve A. Clark was summoned for jury duty in the mail fraud trial of William B. Foshay and others.
- Clark had previously worked for the Foshay Company as a stenographer for about two weeks in 1929, and her husband had a cordial business relationship with Foshay.
- After being informed that her prior employment would likely disqualify her, Clark told other prospective jurors that she had a special reason for wanting to serve on the jury.
- During the voir dire examination under oath, the judge asked Clark about her prior employment history.
- Clark listed several past jobs but deliberately omitted her employment with the Foshay Company.
- Clark also falsely stated that her mind was free from bias and that she would base her verdict solely on the evidence and the law.
- After being selected, Clark served on the jury, which, after an eight-week trial, was unable to reach a verdict.
- During deliberations, Clark was the sole juror voting for acquittal and refused to engage in meaningful discussion with the other eleven jurors.
Procedural Posture:
- The United States government filed an information in the U.S. District Court for the District of Minnesota, initiating criminal contempt proceedings against Genevieve A. Clark.
- The District Court, after a hearing before two judges, found Clark guilty of criminal contempt.
- Clark, as appellant, appealed the conviction to the United States Circuit Court of Appeals for the Eighth Circuit.
- The Circuit Court of Appeals affirmed the conviction but remanded the case for correction of an error in the sentence.
- The United States Supreme Court granted Clark's petition for a writ of certiorari to review the judgment of the Circuit Court of Appeals.
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Issue:
Does a juror commit punishable criminal contempt by deliberately concealing information and giving false answers during voir dire to secure a place on the jury with the intent to obstruct justice?
Opinions:
Majority - Mr. Justice Cardozo
Yes. A juror commits punishable criminal contempt when they deliberately conceal information or lie during voir dire with the intent to obstruct the administration of justice. The petitioner's conduct was a willful and deliberate endeavor to thwart the process of inquiry and turn the trial into a futile exercise. Her concealment of her prior employment with the Foshay Company, coupled with her false statements about her impartiality, was not mere perjury but an abuse of her function as a juror, an officer of the court. This deceit tainted her relationship with the court from its origin, making her a 'partisan defender' rather than an impartial arbiter. Furthermore, the privilege that normally protects the secrecy of jury deliberations does not apply where the juror's position was obtained through fraud. Evidence of her conduct during deliberations was admissible as corroboration of the corrupt state of mind she possessed when she made the false statements during voir dire.
Analysis:
This decision establishes that deceit during voir dire can be punished as criminal contempt, reinforcing the court's authority to protect the integrity of the jury selection process. It creates a significant exception to the long-standing privilege of secrecy for jury deliberations, allowing that privilege to be pierced upon a prima facie showing that a juror gained their seat fraudulently. The case distinguishes between mere perjury by a witness and the more serious offense of a prospective juror lying to infiltrate and corrupt the judicial process itself. This precedent empowers courts to investigate and punish conduct that undermines the foundation of a fair trial by an impartial jury.
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