Remmer v. United States

Background

A man convicted of trying to evade federal income taxes said a juror was approached during the trial by an outsider who hinted about money and a deal. The juror told the trial judge, who informed the prosecutor and involved an FBI agent. The defendant only learned about these events after the verdict and sought a hearing. Lower courts held hearings and reviewed the record several times before the case reached the Court again, focused on whether the outside contact and later investigation harmed the defendant’s right to a fair trial.

Reasoning

The Court examined whether the juror’s outside contact and the subsequent FBI interview together undermined the juror’s freedom to decide the case. Looking at the whole situation, the Court found the juror was disturbed and remained unaware of the true nature and outcome of the investigation while the trial continued. The Court said that private communications or tampering with a juror are presumed to be harmful unless made openly under known court rules. Because that presumption was not dispelled here, the Court concluded the trial was tainted and ordered a new trial.

Real world impact

The ruling requires courts to consider both informal outside approaches to jurors and any follow-up investigations when deciding fairness. Defendants can get new trials where jurors were exposed to unauthorized contacts and investigatory steps that leave them troubled. The decision emphasizes protecting jurors from outside influence to preserve the integrity of verdicts.