Martha stewart trial facts

S Court of Appeals. They did the same in the second circuit of her appeal. In the appeal, Martha Stewart claimed that she had been a victim of a trial that was unfair. The appeals of Martha Stewart were brief and concise, made public and indicated that the jury ought to have understood the difference between deceiving and insider trading of securities.

The leader of the appeal, Dellinger, requested that a new trial be done on the same case by forwarding his request to the Department of Probation. In fact, Dellinger argued that the trial judge was not in any case reasonable and the court ought to hold any sentence pending the appeal. Despite the fact that most of the statements made by the witnesses of the case were allowed to stand, Dellinger still decided to move ahead and dispute the facts alleged against his client.

Following the appeals, Martha Stewart was released in March since she had won in the appeals Schwartz, , p. It is important to note that the conviction of Martha Stewart had significant impact on her image, given the fact that she had much publicity through her career as a TV personality and an author of famous magazines.

Ackman, D. Martha Stewart Found Guilty. Meier, B. The New York Times. Schwartz, J. Need a custom Term Paper sample written from scratch by professional specifically for you? The Martha Stewart Trial. We use cookies to give you the best experience possible. Sullivan , F. The need for a new trial depends on the effect of the perjury on the verdict, see Stofsky , F.

Guariglia , F. The standards for assessing materiality in the two contexts reflect the different purposes effectuated by the rule and the statute. The materiality inquiry in a Rule 33 motion focuses on the ultimate outcome of the trial because the objective of the rule is to relieve a defendant of the unfairness that results when false testimony contributes to a verdict of conviction. Section , on the other hand, serves to deter and punish false testimony and may be based more broadly on any matter before the jury.

Reed , F. Gugliaro , F. Birrell , F. In sum, we find that the interests of justice do not require a new trial because Lawrence's false testimony did not result in unfairness to Defendants. The District Court did not err in finding that there is no reasonable possibility, much less a probability, that the jury's decision to convict Defendants for lying about their various communications on and after December 27th would have been different if the jurors had known the facts that Lawrence concealed or had known that Lawrence lied under oath.

Nor did the District Court abuse its discretion by denying Rule 33 relief without convening an evidentiary hearing to ascertain the extent of the Government's awareness of the perjury.

Where, as here, the additional evidence of perjury is not sufficiently material to undermine confidence in the verdict, there is no need to probe the extent of the Government's awareness of the perjury because the argument fails under either standard.

The District Court's denial of Defendants' Rule 33 motions based on Lawrence's testimony is affirmed in all respects. Defendants charge that the District Court erred by denying Rule 33 relief without holding an evidentiary hearing on alleged juror misconduct. Defendants claim that evidence indicating that juror Chappell Hartridge gave false voir dire responses justified further inquiry into his ability to be fair and impartial.

Bacanovic makes the additional argument that a new trial, or at least an evidentiary hearing, is warranted because post-verdict public statements by Hartridge and other jurors demonstrate that matters outside of the record improperly influenced the verdict of conviction. Post-trial jury scrutiny is disfavored because of its potential to undermine "full and frank discussion in the jury room, jurors' willingness to return an unpopular verdict, and the community's trust in a system that relies on the decisions of laypeople.

Accordingly, probing jurors for "potential instances of bias, misconduct or extraneous influences" after they have reached a verdict is justified "only when reasonable grounds for investigation exist," in other words, where there is "clear, strong, substantial and incontrovertible evidence that a specific, nonspeculative impropriety has occurred which could have prejudiced the trial. Moon , F. United States , F. The inquiry should end whenever it becomes apparent to the trial judge that "reasonable grounds to suspect prejudicial jury impropriety do not exist.

We review for abuse of discretion the District Court's Rule 33 decision regarding the effect on the jury of "potentially prejudicial occurrences. Reviewing the District Court's denial of Rule 33 relief based on alleged juror bias, we are mindful of the principle that.

Phillips , U. Voir dire examination serves to protect that right by exposing possible biases, both known and unknown, on the part of potential jurors. Demonstrated bias in the responses to questions on voir dire may result in a juror being excused for cause; hints of bias not sufficient to warrant challenge for cause may assist parties in exercising their peremptory challenges.

The necessity of truthful answers by prospective jurors if this process is to serve its purpose is obvious.

McDonough Power Equip. Greenwood , U. These concerns are reflected in the McDonough standard for analyzing allegations that a juror's false voir dire concealed bias that affected the fairness of the trial: a party alleging unfairness based on undisclosed juror bias must demonstrate first, that the juror's voir dire response was false and second, that the correct response would have provided a valid basis for a challenge for cause.

See McDonough , U. The District Court observed that this Court has never found reason to overturn a verdict on the basis of juror nondisclosure under McDonough and only once, see United States v.

Colombo , F. Our ruling here does not change those statistics. Prompted by the extensive publicity surrounding this case, the District Court undertook a two-step voir dire process. First, prospective jurors completed a questionnaire drafted by the parties. Then, following for-cause challenges based on the questionnaire responses, those persons remaining in the jury pool were questioned individually.

The questionnaire probed prospective jurors' prior involvement with the justice system by asking about court appearances and whether the individual or someone close to him or her had filed criminal charges, had been the victim of a crime, had been sued, accused of wrongdoing on a job, or questioned by law enforcement or accused of, charged with, or convicted of any crime.

Hartridge's questionnaire reflected that he had appeared in court in connection with a dispute with his landlord, but he gave negative responses to the other questions described above.

He returned for individual questioning and was subsequently empaneled. Shortly after the jury's verdict was announced, Hartridge and several other jurors discussed their experience as jurors with the press.

According to Defendants, at that time "the defense received information calling into question the manner in which Hartridge got on the jury. In their motions for a new trial, Defendants alleged that Hartridge's failure to disclose the following five matters on his questionnaire concealed probable bias: i an arrest and arraignment for assault of a former girlfriend; ii civil suits against Hartridge and members of his family; iii his son's conviction for attempted robbery; iv an accusation of embezzlement in his capacity as a Little League volunteer treasurer; and v termination for cause from employment with Citibank.

As support, Defendants proffered affidavits, only one of which was based on personal knowledge, and court records. The District Court found that the majority of Defendants' allegations did not satisfy the first prong of the McDonough test because they rested on "little more than hearsay, speculation, and in one instance, vague allegations made by a person who refused to identify himself.

The District Court also found that certain ambiguities in the voir dire questions developed by the parties made it unclear that Hartridge's responses deliberately concealed the truth. As to those alleged failures to disclose, this was not the type of showing that constitutes "reasonable grounds" for investigation. The District Court credited Defendants with raising serious questions concerning deliberate concealment of two matters that Hartridge did not disclose, namely, the conviction of Hartridge's son for attempted robbery in and a civil judgment against Hartridge and his wife in , both of which were supported by objective evidence.

But the District Court found that none of the alleged omissions satisfied the second part of the McDonough test, which requires the party seeking a new trial to demonstrate that the correct answer at jury selection would have provided a valid basis to challenge the prospective juror for cause.

McDonough , U. To do so, the district court must "determine if it would have granted the hypothetical challenge.

Greer , F. Ploof , F. Defendants contend that the juror's multiple failures to disclose background information indicate a suspicious pattern sufficient to raise doubts about his impartiality which justifies further inquiry in a hearing. For this proposition, Defendants cite a decision in which the Ninth Circuit observed that certain false statements that "might be harmless in isolation" may present a "much more sinister picture" when viewed as a whole.

Green v. The assertion that Hartridge engaged in a pattern of lies ignores the District Court's finding, which is not clearly erroneous, that only two of the alleged intentional omissions were supported with the type of evidence that justifies further inquiry. In Green , the Ninth Circuit found error in the trial court's finding of no bias where the juror not only lied twice about his background but gave misleading and false explanations when confronted with the lies and also made comments i.

In this case, the allegations form a pattern that might create "destructive uncertainties" about Hartridge's indifference if they were proved, id.

Calderon , F. Nor is Colombo to the contrary. In Colombo , a district court's decision to refuse Rule 33 relief on the basis of alleged false voir dire responses was vacated and the case was remanded for an evidentiary hearing. The alleged false responses asserted by Stewart and Bacanovic differ distinctly from the ones at issue in Colombo. There, the defendant's Rule 33 motion was supported by an alternate juror's affidavit, which stated that one of the jurors i confided that she failed to disclose that her brother was a government attorney because she feared the relationship would make her ineligible to serve on the jury and ii asserted familiarity with one of the conspirators' meeting places as a "hang out for gangsters.

In Colombo , "it was not simply that the lies in question were deliberate, but that the deliberateness of the particular lies evidenced partiality. Thus, where the Colombo affiant specifically asserted that the juror admitted not only concealment, but concealment of facts from which specific bias could be inferred, the alleged lies, if established, would demonstrate both dishonesty and partiality and would satisfy both prongs of the McDonough test.

That is not the case here. Defendants note that all of the jury bias cases cited by the District Court involved post-trial hearings. See Greer , F. Shaoul , 41 F. Langford , F. In the present case, the District Court did not abuse its discretion in refusing to conduct a hearing because it found that even if all of the allegations were established by competent evidence, none would provide valid grounds to challenge for cause Hartridge's membership on the jury.

Moten , F. We therefore caution district courts that, if any significant doubt as to a juror's impartiality remains in the wake of objective evidence of false voir dire responses, an evidentiary hearing generally should be held. Boney , F. Such a hearing is often the most reliable way for discerning the true motivations behind a juror's false replies. See Smith , U. Here, however, although we might have ruled differently on the hearing request in the first instance, we cannot say that the District Court's decision was an abuse of discretion.

See Moon , F. During the course of a televised interview shortly after the verdict was returned, jurors were asked what they thought about the testimony of Stewart's friend, Mariana Pasternak. Their responses give rise to Bacanovic's argument that the jury impermissibly considered matters outside the record in reaching the verdict as to him. During direct examination by the Government, Pasternak testified that while vacationing with Stewart at the end of December , she "recall [ed] Martha saying that [Sam Waksal's] stock is going down, or went down, and I sold mine.

On cross-examination, Pasternak stated that she could not remember with certainty whether the statements she attributed to Stewart were actually made by Stewart or whether they were Pasternak's own thoughts.

Bacanovic's motion for a mistrial was denied, and prior to cross-examination of Pasternak, the District Court instructed the jury as follows:.

Testimony about what Martha Stewart told Ms. Pasternak is received in evidence only with respect to Martha Stewart. None of the statements of Martha Stewart to Ms. Pasternak that you heard yesterday afternoon are received in evidence against Peter Bacanovic, and it is not evidence against Peter Bacanovic.

So that remember I told you at the beginning of the trial that guilt is personal, that you must separately consider each defendant and each charge. In considering the charges against Peter Bacanovic, you may not consider the testimony about those statements of Martha Stewart to Ms. Pasternak in any respect. They have no bearing as to Peter Bacanovic. The jury received similar limiting instructions in the jury charge at the close of evidence. Bacanovic now contends that certain public remarks by Hartridge and other jurors reveal that the jury did consider Pasternak's testimony in connection with the charges against him.

In the interview, jurors were asked the following questions about the portion of Pasternak's testimony quoted above: "What did you think when she said that?

It took down two people with one shot because she mentioned Peter's name. Bacanovic asserts that these remarks indicate that his conviction was improperly influenced by extra-record prejudicial material, and that the District Court erred by denying his motion for a new trial and his request for an evidentiary hearing in holding, in part, that Hartridge's statement was inadmissible under Fed. Bacanovic argues that the juror's statement regarding Pasternak's testimony falls within the exception to Rule b because i it was outside the record, as the record pertained to him and ii was highly prejudicial because it was the only evidence corroborating Faneuil's testimony that Bacanovic was involved with telling Stewart that Waksal was attempting to sell his stock.

According to Bacanovic, a ruling against him on this point would have the effect of barring, under Rule b , testimony that the jury improperly considered evidence extraneous to one defendant in a multi-defendant trial, where Rule b would permit such testimony from a juror regarding the same extraneous evidence if the defendant was tried alone.

We do not agree with that articulation of the issue. In fact, a ruling in Bacanovic's favor would enable an end-run around the well-settled proposition that jurors are presumed to follow instructions, see, e. Downing , F. Nat'l Football League , F. In so deciding, we agree with the Eighth Circuit's decision to reject an argument, similar to Bacanovic's, that Rule b did not prohibit the trial court from inquiring about jurors' alleged discussion of the defendant's failure to testify.

Rodriguez , F. The Eighth Circuit responded,. That [defendant] did not testify is not a fact the jurors learned through outside contact, communication, or publicity. It did not enter the jury room through an external, prohibited route. It was part of the trial, and was part of the information each juror collected. It should not have been discussed by the jury, and indeed was the subject of a jury instruction to that effect.

But it was not "extraneous information," and therefore does not fall within the exception outlined in Rule b. Here, as in Rodriguez , the alleged impermissible influence was not the result of information "the jurors learned through outside contact, communication, or publicity" or that "enter [ed] the jury room through an external, prohibited route. Goord , F. Louisiana , U.

As such, the testimony cannot be considered extraneous information. Stewart and Bacanovic argue that they were prejudiced by the specter of an uncharged offense. They assert that the trial was infected by language and evidence concerning insider trading.

The dispute over this issue arose early in the proceedings, when Stewart moved to strike portions of the Superseding Indictment, alleging that it invoked facts, theories and terminology that were relevant only to the crime of insider trading, which was not charged.

The Government moved in limine to preclude the defense from arguing that jurors could draw an inference from the fact that Stewart was not charged with insider trading. The District Court granted the Government's motion and established the following ground rules for trial:. The Government seeks to prevent defendants from inviting the jury to speculate about why the indictment does not charge the crime of insider trading.

Clearly, defendants may inform the jury that the indictment does not charge them with the crime of insider trading. But defendants may not invite the jury to speculate as to why that charge was not included in the indictment.

Nor may they argue that the absence of an insider trading charge proves their innocence of such activity. If the Government presents arguments or evidence that tend to show that defendants were motivated not only by the fear that they would be accused of trading illegally, but also that such a fear was justified — that is, that Stewart's trading was illegal — then it will open the door to defense evidence that the conduct was not illegal.

Accusations by each side that the other side failed to comply with the ruling were first lodged during opening statements and repeated throughout the trial.

In rulings made in connection with the issue, the District Court drew a distinction between 1 Stewart's state of mind, or belief, regarding the possibility that her ImClone sale would result in insider trading charges, and 2 whether the ImClone sale transaction was actually illegal as a matter of fact or law. The former was relevant to the charged offenses; the latter was not.

Defendants now challenge the District Court's refusal to instruct the jury that Defendants were not charged with insider trading. They also argue that the District Court made erroneous evidentiary rulings, including preventing Stewart's securities law expert from testifying, that unfairly restricted their right to present a complete defense. Defendants contend that the District Court erred by failing to instruct the jury, as proposed in Stewart's Request Number 17, that.

Your deliberations are limited to the facts that have been proved in court during the course of this trial. Thus you may only consider that which was presented in court in relation to the charges in the Indictment. You may consider Insider Trading only insofar as it pertains to motive for the obstruction charge. The government contends that information about the Waksal sales was believed by Ms. Stewart to constitute inside information.

Stewart vigorously denies that she so believed or that it was her intention to violate the law by trading on this type of information. You may not, and I caution you strongly against this, you may not conclude that the government should have charged Ms.

Stewart with Insider Trading and convict her of anything else in place of a charge that was not filed by the government and charged by the grand jury because it appeals to your sense of fairness or justice or what have you. You may not convict Martha Stewart unless there is sufficient evidence independent of Insider Trading to support a conviction on the charge in question.

It is not clear that Defendants preserved this argument because the request was not discussed at the charge conference, nor was there any explicit objection to its omission. We need not resolve the waiver issue, however, because the argument fails whether we review the District Court's decision de novo, see, e. Gonzalez , F. Crowley , F. In charging the jury, the District Court identified each specific charge against each Defendant and instructed the jury as to the elements essential to convicting each Defendant on each count as well as the necessity that the elements be proved beyond a reasonable doubt to support a guilty verdict.

In addition, the jury received a copy of the Redacted Superseding Indictment and a verdict sheet that identified each specification in each count against each Defendant. The jury was directed to weigh the evidence and reach a verdict based solely on a consideration of the evidence and the instructions, and the District Court stressed that "it would violate your sworn duty to base a verdict upon any other view of the law than that which I give you.

Holland , F. Han , F. We "look at the charge as a whole to see if it correctly stated the law," United States v.

Jones , 30 F. Alfisi , F. Defendants do not cite any precedent for finding that a trial was unfair because the jury did not receive an instruction not to consider culpability for specified uncharged crimes, where the instructions were otherwise proper.

The District Court's instructions were sufficient to restrict the jury's use of the evidence to the crimes charged. It is clear from the partial verdict of acquittal that the jury "carefully evaluated the evidence and rendered [a] discriminating verdict [ ]" and not one that was based on uncharged acts or bad character.

Casamento , F. Diaz , F. Certainly, the theory that Defendants should not be convicted for uncharged conduct was effectively presented elsewhere in the charge, namely in the portion devoted to explaining the elements that must be found beyond a reasonable doubt in order to convict. See Holland , F. The District Court gave clear instructions as to the charges against each Defendant and the type and quantum of evidence on which to base a guilty verdict.

We presume that juries follow their instructions, and the record does not suggest that the jurors were either confused or prejudiced against Defendants in determining the counts of conviction. Geibel , F. Allen v. On this record, therefore, we find that the District Court did not err by omitting Stewart's Request Number 17, much less commit plain error.

Carr , F. Defendants assert that several of the District Court's evidentiary rulings interfered with their rights to present a meaningful defense by calling witnesses on their behalf and cross-examining prosecution witnesses.

Most of the challenged rulings pertain to the insider trading issues. These rulings precluded Defendants from calling a securities law expert, and imposed limitations on direct examination of Stewart's business manager, Heidi DeLuca, and on cross-examination of Faneuil.

Almonte , F. It is equally well-settled that the right is subject to the application of procedural and evidentiary rules. Mantello , F. Restrictions on presenting evidence do not offend the Constitution if they serve "legitimate interests in the criminal trial process" and are not "arbitrary or disproportionate to the purposes they are designed to serve.

Arkansas , U. Similarly, the right to confront and cross examine witnesses is tempered by a trial judge's "wide latitude" to impose "reasonable limits" in order to avoid matters that are confusing or of marginal relevance. Howard v. Walker , F. Clearly, " [t]he accused does not have an unfettered right to offer testimony that is incompetent, privileged, or otherwise inadmissible under standard rules of evidence.

Illinois , U. We review a trial court's evidentiary rulings, including the decision to admit or exclude expert testimony, for abuse of discretion. City of New York , F. Anglin , F. Duncan , 42 F. Her mother taught her how to cook, bake, and sew, while her father taught her how to garden as a young child. Martha Stewart is big animal lover, owning several dogs, cats, birds, chickens, turkeys, donkeys, and horses. Martha Stewart has had a hand in TV, magazines, books, radio, digital content, mass-market homeware production, food wares, and real estate among others.

She earned a bachelor's degree from Barnard College in history and architectural history. Martha Stewart at one point was dating Sir Anthony Hopkins, but broke things off after watching The Silence of the Lambs , stating that she couldn't help associating Hopkins with the Hannibal Lecter character.

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