United States v. Shkreli

264 F. Supp. 3d 417
Procedural entryThis page is a short order in United States v. Shkreli. Read the opinion of the Court — 260 F. Supp. 3d 247
District Court, E.D. New York·Decided August 18, 2017·No. 15-CR-637 (KAM)·Published

Opinion

MEMORANDUM AND ORDER

MATSUMOTO, United States District Judge:

The court assumes familiarity with the facts of this case, which commenced on June 28, 2017 and was tried to verdict on August 4, 2017. Now before the court is a request from Bloomberg L.P., The. Associated Press, Reuters, The New York Times Co., Daily News L.P. and NYP Holdings, Inc, (collectively, the “Press Organizations”), that the court “promptly disclose the names of the jury members” in this case. (Letter dated August .11, 2017, EOF No. 308 at 1.)

Before jury selection, members of the Eastern District of New York press pool1 requested that one pool reporter be permitted to be present at side bar discussions with individual potential jurors during voir dire. (Press Email at 1.) The defense opposed the request, arguing that “Mr. Shkreli’s right to a fair trial trumpfed] the media’s First Amendment right”. (Defense Letter in response to request from EDNY press pool, EOF No. 254 at 3.) The court conducted jury selection in open court and granted the press pool’s request to have a reporter present at sidebar when venire members were examined individually; In order to safeguard Mr. Shkreli’s Sixth Amendment right to a fair trial by ensuring candor among, prospective jurors in this high-profile case, the court ordered, that the names of the jurors would not be released publicly by the court until the conclusion of trial, and that juror names would be disclosed to, but were not to.be used by, the parties during the trial. (EOF No. 259; see ABC v. Stewart, 360 F.3d 90, 104 (2d Cir. 2004) (proposing “concealing the identities of the prospective jurors” in order to “ensure juror candor” during voir dire)). The press was also prohibited from taking pictures or sketching the faces of any juror or potential juror in this case within the courthouse. (EOF No. 259.) During trial, for the sake of convenience and in keeping with the undersigned judge’s usual practice, the court referred to jurors by number rather than name. Thus, although the court did not explicitly preclude the press from printing the names of jurors, and did not empanel an anonymous jury or sequester the panel of jurors and alternates, members of the press would not have been able to learn the names of jurors without resorting to invasive investigatory tactics.

Mr. Shkreli has opposed the Press Organizations’ request for post-trial disclosure of juror names on the grounds of juror privacy, and' also argues that the Second Circuit has not mandated that juror names be disclosed to the press. (Defendant’s Letter dated August 14, 2017, EOF No. 313.) The government has taken no position on the Press Organizations’ request. (Letter dated August 15, 2017, EOF No. 319.)

Although the Second Circuit has not addressed whether a court must release juror names post-verdict when the names were not disclosed to the public during trial based on specific findings, the [419]*419Supreme Court and Second Circuit have emphasized that there is a “presumption of openness” for judicial proceedings. Stewart, 360 F.3d at 98 (2d Cir. 2004) (quoting Press Enterprise Co. v. Superior Court, 464 U.S. 501, 510, 104 S.Ct. 819, 78 L.Ed.2d 629 (1984). Although “[t]he constitutional right of access” to judicial proceedings “is not absolute, and must, in certain circumstances, give way to other rights or interests, such as the defendant’s Sixth Amendment right to a fair trial or the privacy interests of prospective ju-rorsf,] ... [t]he presumption of openness may be overcome only by an overriding interest based on findings that closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Id.

In this case, the court’s earlier decision requiring that the parties and court staff refrain from disclosing juror names effectively operated as a form of narrowly tailored closure, limiting information' that the press may have been able to gather absent the order. (See ECF No. 259.) As the court detailed in that order, this limited restriction was necessary to safeguard Mr. Shkreli’s Sixth Amendment right to a fair trial.

Now that the jury has returned a verdict, the défendant’s concerns about his right to a fair trial are moot, but the court must nonetheless take into account the privacy interests of the jury. Of the nine jurors successfully contacted by the court, seven jurors expressed a preference that their names not be disclosed; only two jurors expressed indifference to the disclosure of their names.2 Multiple jurors mentioned that they would prefer that their names not be associated with a high-profile case. Most jurors also noted that they would prefer not to speak to the press. All jurors are entitled to refuse press interviews if contacted.

Jury deliberations are, and should remain, confidential. “The secrecy of deliberations is the cornerstone of the modem Anglo-American jury system,” and “disclosure of the substance of jury deliberations may undermine public , confidence in the jury system.” United States v. Thomas, 116 F.3d 606, 618 (2d Cir. 1997); In re Globe Newspaper Co., 920 F.2d 88, 94 (1st Cir. 1990) (noting that there is “no public right of access” to jury deliberations). Indeed, the Supreme Court has recognized that “[fjreedom of debate might be stifled and independence .of thought checked if jurors were made to feel that their arguments and ballots were to be freely published to the world.” Id. at 619 (quoting Clark v. United States, 289 U.S. 1, 13, 53 S.Ct. 465, 77 L.Ed. 993 (1933)).

Despite the long and challenging service of the jury members and the court’s profound gratitude for their service and attention throughout the trial, the privacy interests and preferences of the jury alone aré generally insufficient to preclude disclosure of their names. Press-Enterprise, 464 U.S. at 512, 104 S.Ct. 819 (in dicta, suggesting that a court could not withhold' a juror’s name from voir dire transcripts unless there was a specific “significant” and “valid privacy interest” such that withholding a name was necessary “to protect the person from embarrassment”); United States v. Wecht, 537 F.3d 222, 240 (3d Cir. 2008) (“we cannot accept the mere generalized privacy concerns of jurors as a sufficient reason to conceal their identities in every high-profile case” (quoting Globe Newspaper, 920 [420]*420F.2d at 98)). Because the trial has concluded, the court does not have a continuing basis to make particularized findings concerning the defendant’s right to a fair trial and the risks to juror privacy that would warrant the continued enforcement of its prior order. Here, there is no evidence that the security of any juror would be placed at risk. Nor would defendant’s right to a fair trial be implicated post-verdict.

Free access — add to your briefcase to read the full text and ask questions with AI

United States v. Shkreli, 264 F. Supp. 3d 417 (E.D.N.Y. 2017).

264 F. Supp. 3d 417 (United States v. Shkreli) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Clark v. United States
289 U.S. 1 (Supreme Court, 1933)
United States v. Rod Blagojevich
612 F.3d 558 (Seventh Circuit, 2010)
United States v. Wecht
537 F.3d 222 (Third Circuit, 2008)
United States v. Doherty
675 F. Supp. 719 (D. Massachusetts, 1987)
United States v. Sampson
297 F. Supp. 2d 348 (D. Massachusetts, 2003)
United States v. Thomas
116 F.3d 606 (Second Circuit, 1997)