United States v. Zimny, No. 15-2144 (1st Cir. 2017)Annotate this Case
After a jury trial, Defendant was found guilty of five counts of wire fraud, five counts of engaging in unlawful monetary transactions, two counts of filing false tax returns, and one count of bank fraud. Defendant appealed. In this opinion, the first Circuit addressed only Defendant’s argument that the district court’s inquiry into Defendant’s claims of juror misconduct was inadequate. The First Circuit remanded with instructions that the district court conduct an investigation into the juror misconduct allegations, holding that, under the circumstances of this case, the district court was required to conduct some further inquiry once it was apprised of the potential juror misconduct.