MONTH-IN-BRIEF (Oct 2019)
Increased Privacy Concerns Not Enough to Limit the Disclosure of Juror Information
By Antoine Bedard, Penn State Law
On January 18, 2019, the U.S. Court of Appeals for the First Circuit vacated and remanded a District Court’s order that had limited the disclosure of juror information without making particularized findings to support such a limitation. United States of America v. Glenn A. Chin, 913 F.3d 251 (1st Cir. 2019). The Court of Appeals held that, pursuant to In re Globe Newspaper Co., 920 F.2d 88 (1st Cir. 1990) (“Globe”), the interpretation of the “District of Massachusetts Plan for Random Selection of Jurors” applied and, therefore, the District Court must disclose both a juror’s name and home address post-verdict, absent particularized findings – “credible threats of jury tampering, risk of personal harm to individual jurors, or other evils affecting the administration of justice” – that reasonably justify withholding or delaying the release of such information.