UNITED STATES OF AMERICA v. TRENTON R. BIRCHETTE
US Court of Appeals for the Fourth Circuit, Wilkinson, November 7, 2018,
Jury Trial – Racial Animus – To interview jurors about deliberation, a party must demonstrate that these interviews are likely to find evidence that racial animus was a significant motivating factor in the jury’s decision to convict

Racial Animus – The Supreme Court’s 2017 decision is a narrow exception that only applies where there is information that racial animus was a “significant motivating factor” in convicting the defendant

Racial Animus – A juror’s statement that she was accused by other jurors of holding out on the basis of racial identity with the defendant was not “good cause” to allow the jurors to be interviewed about deliberations

From the Case: “Even accepting, arguendo, that all proffered evidence was reliable, none of the statements here required the district court to find that defendant would likely uncover evidence that “racial animus was a significant motivating factor in the jury’s vote to convict.”

Impeachment – A trial judge is not required to allow the defendant to question officers about previous cases where they acted honestly but evidence was suppressed

From the Case: “The mere fact that a district court disagrees with a law enforcement officer’s assessment of reasonable suspicion or probable cause affords no basis for impugning the officer’s integrity or opening the door to testimony about past conduct.”