United States v. Maloney

Deference is given to trial courts in determining a juror's impartiality and the jury instructions, and a high level of deference is given to a court's decision whether or not closing arguments are proper.

Border Patrol stopped John Maloney at a checkpoint in California. A canine alerted agents to Maloney's tractor-trailer; and he consented to a second sniff, after which he agreed to a search. Agents found over three hundred pounds of marijuana in the cab of the vehicle. A jury found Maloney guilty of knowingly and intentionally possessing marijuana with the intent to distribute. Maloney appealed, arguing the district court abused its discretion in various technical aspects of the trial, warranting reversal. The Court held the district court did not abuse its discretion in denying Maloney's motion to excuse a juror for cause because that juror “definitively and unequivocally” stated he could be impartial and set aside his past experience with law enforcement. Deference is due the district court in making this decision, and Maloney must show actual bias in order to carry his burden of proof. The Court also held the district court did not abuse its discretion in rejecting a jury instruction concerning Maloney's character, because another instruction covered the proposed instruction's substance. Maloney argued the given instruction did not accurately state his case and identify the correlation between good character and reasonable doubt. The Court disagreed, and found the given instruction adequately covered the issues. Maloney's final argument was the district court abused its discretion by denying rebuttal, and allowed the prosecution to make new arguments during closing argument. The Court determined there is a high level of deference given to the district court in determining whether rebuttal summation is proper, and the district court did not abuse its discretion in this case. Maloney opened the door to his credibility, and the prosecution made permissible inferences from the record to cast doubt on Maloney's credibility. The Court also held any error by the district court was harmless. AFFIRMED.