Clark v. United States
United States Court of Appeals for the Eighth Circuit
61 F.2d 695 (1933)
Relevant factsFree
Genevieve Clark (defendant) was the lone holdout juror in a criminal trial that ended in a deadlocked jury, and was later charged with contempt for failing to disclose, during voir dire, her bias in favor of the defendant. Clark was convicted after a bench (non-jury) trial. On appeal, she argued the contempt-trial judge improperly admitted the criminal jury's internal deliberations into evidence against her.
IssueFree
Whether, on appeal of a non-jury trial's verdict, the trial judge is presumed to have considered only admissible evidence.