United States v. Cortez Lorenzo Hill -Eastern District of Michigan at Detroit
Split Score
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This score (0-100) indicates how likely this case is to be reviewed by the Supreme Court based on:
Case Summary
Disposition
Affirmed
The Sixth Circuit affirmed Cortez Hill’s convictions for conspiracy to distribute heroin and possession with intent to distribute. The court rejected Hill’s arguments that the evidence proved multiple conspiracies, that evidence of constructive possession was insufficient, and that juror misconduct required a mistrial.
Circuit Split Identified
Legal Issue
Whether a presumption of prejudice applies when jurors are exposed to extraneous information and, if so, which party bears the burden of proving harmlessness or actual partiality.
Circuit Positions
Presume prejudice from extraneous juror communication; burden shifts to government to prove harmlessness.
No presumption of prejudice; defendant must demonstrate actual juror partiality.
Conflict Summary
The Fourth Circuit presumes prejudice from any extraneous juror communication and places the burden on the government to rebut that presumption, while the Sixth Circuit does not presume prejudice and requires the defendant to affirmatively show actual juror partiality.