Page 8 - The People of the State of New York v. M. Robert Neulander - Brief for Amicus Curiae in Support of Defendant-Respondent

subsequently perjuring herself
justice by destroying evidence.
ultimately revealed the level of
is so great, and the impropriety of

obstructs justice through this degree of
3

The extent of
her misconduct.

clear, that a new trial is required to protect the integrity of

impartial juror, but Juror 12 in this case was anything but honest.
her misconduct and denied having violated the court's instructions.
once (but likely more often) performing prohibited internet searches.

our system of
It has long been established that honesty is a vital characteristic of
she took deliberate steps to obstruct justice and cover up her dishonesty by
an
cumulative deceitful misconduct, she
entire internet browsing history, and resisted producing her cell phone, which
Instead, her
compounded her misconduct by lying to the court in chambers during the trial,
She then
her ~aving served as a juror in this case is so
The NYCDL respectfully submits that when a juror is this dishonest and
In addition,
justice.
communicating via text with various third parties about the case, and by, at least
dishonesty began during the trial, when she disobeyed the court's instructions by
in a post-trial affidavit, which greatly downplayed
during the trial, compounded by her post-trial perjury and her attempts to obstruct
Fourth Department would uphold a conviction despite a juror's blatant dishonesty
selectively deleting from her cell phone numerous inculpatory texts, as well as her
this misconduct at trial and afterward
when honest answers would have led immediately to her removal as a juror, and by