Dishonest answers by jurors
Nix v. United States
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Matthew Nix asked which test courts should use to decide whether a juror’s honest answer during jury selection would have supported removing the juror for cause in a request for a new trial based on juror dishonesty.
- Who it affects
- Nix received no Supreme Court ruling on which test applies to his juror-dishonesty claim.
Summary: written with AI from the case record.

What it's about
The Supreme Court refused to hear the case (denied review), so it did not decide which test applies.
The question concerns when a juror's dishonest answer during jury selection can support a request for a new trial.
Question presented
In applying McDonough's second prong, which asks whether "a correct response would have provided a valid basis for a challenge for cause," should a court apply a) the Third, Sixth, and Eleventh Circuits' traditional for-cause-challenge test, under which it is enough that a correct answer would have supported a challenge for cause; b) the First and Second Circuits' trial-court-discretion test, under which relief rests in the court's discretion and no formal for-cause basis is indispensable; c) the Fourth and Eighth Circuits' test requiring a for-cause basis plus a showing that the juror's motivation affected the fairness of the trial; or d) the D.C. Circuit's test requiring a for-cause basis plus a showing of actual bias?
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
More questions
- What different tests did Nix ask the Court to consider?
- They ranged from asking whether a truthful answer supported removing the juror for a stated reason to requiring added proof of unfairness or actual bias; another approach leaves relief to the trial judge's discretion.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.