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United States v. Littlefield
United States Court of Appeals for the Ninth Circuit
752 F.2d 1429 (1985)
Jean Littlefield, George Nicoladze, and Fred Solomon (defendants) were tried for crimes related to fraudulent tax shelters. During jury deliberations, one of the jurors took a Time magazine article on similar fraudulent tax shelters into the jury room and discussed it with other jurors. The jury ultimately convicted Littlefield, Nicoladze, and Solomon, who challenged the verdict. The district court found that it could be concluded that the article did not bias the jury. Littlefield, Nicoladze, and Solomon appealed their convictions. The United States (government) (plaintiff) argued in opposition to the appeal that pursuant to Smith v. Phillips, 455 U.S. 209 (1982), the defendant and not the government bears the burden of proving jury bias.
Rule of Law
Holding and Reasoning (Goodwin, J.)
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