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Case 1:20-cr-00330-PAE Document 643 Filed 03/11/22 Page 26 of 49 that “personal experiences” are “permissible influences on jury deliberations”); Arreola v. Choudry, 533 F.3d 601, 606 (7th Cir. 2008) (jurors “are entitled to evaluate the evidence presented at trial in light of their own experience’’). Thus, so long as they do not introduce extra-record facts about the defendant, there is nothing improper about jurors bringing their personal experiences to bear during deliberations. McMann, 435 F.2d at 818 & n.5. Here, if Juror 50 had disclosed a history of sexual abuse, there is every indication that the voir dire would have proceeded as it did with the numerous similarly situated jurors. The Court would have asked follow-up questions—substantially similar to the Second Circuit-approved question above—designed to determine whether he could be fair and impartial. If he had credibly disclaimed partiality, he would not have been struck from the jury. ii. Implied Bias Implied bias, also called “presumed bias,” is “‘bias conclusively presumed as a matter of law.’” Torres, 128 F.3d at 45 (quoting Wood, 299 U.S. at 133). That is, a finding of implied bias does not turn on the juror’s answers to questions during voir dire, but rather whether an “average man” in a similar situation would be biased. /d. at 45-46. The Second Circuit has emphasized that this category is “narrow,” and “reserved for ‘exceptional situations.’” /d. at 46. Generally, it is limited to circumstances in which there is a relationship between the juror and the parties or the crime itself. See id. at 45 (“[A ]utomatically presumed bias deals mainly with jurors who are related to the parties or who were victims of the alleged crime itself.”); Greer, 285 F.3d at 172 (“[T]he District Court refused to find implied bias because it found the issues affecting juror Baker to be insufficiently ‘drastic.’ Juror Baker was, after all, neither related to a party nor a victim of the defendants’ crimes.”). 24 DOJ-OGR- 00009824