The Fifth Circuit Court of Appeals found that the trial court in U.S. vs. Gemar abused its discretion by failing to investigate juror bias alleged when juror was found to have been a close friend of the defendant's wife. The trial judge failed to hold a hearing and the appeals court remanded the case for the court to conduct one. The juror had attended a school dance with her in 1995 or 1996, attended Gemar's wedding, and had been friends on social media. Gemar's wife had been present in the courtroom during the trial.
United States v. Gemar, No.21-30666 (5th Cir. Apr. 19, 2023)
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