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Clark v. United States

United States Court of Appeals for the Eighth Circuit
61 F.2d 695 (1933)


The jury in a criminal case was unable to reach a verdict. Genevieve Clark (defendant) was the lone holdout juror. Clark probably would not have been selected as a juror had she, on voir dire, disclosed her association with and bias in favor of the defendant. For that non-disclosure, the United States (plaintiff) charged Clark with contempt of court. Clark was convicted after a non-jury trial. On appeal to the United States Court of Appeals for the Eighth Circuit, Clark contended that the contempt trial's judge improperly admitted the criminal trial's jury discussions into evidence.

Rule of Law


Holding and Reasoning (Kenyon, J.)

Dissent (Gardner, J.)

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