9th U.S. Circuit Court of Appeals
Jul. 22, 2026
Failure to probe alternate juror bias dooms PPP fraud convictions
A unanimous 9th U.S. Circuit Court of Appeals ruled that a federal judge failed to adequately investigate an alternate juror who expressed apparent bias before trial and later joined deliberations, vacating a defendant's 44 convictions in a Paycheck Protection Program fraud case.
A unanimous 9th U.S. Circuit Court of Appeals panel on Tuesday vacated the convictions of a man convicted on 44 federal charges arising from a Paycheck Protection Program fraud scheme, holding that the trial judge failed to adequately investigate an alternate juror who expressed apparent bias before trial and later participated in the verdict.
Writing for the panel, 9th Circuit Judge Anthony D. Johnstone said the Sixth Amendment requires trial courts to promptly investigate any co...
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