U.S. v. Daniels

In prosecution on armed bank robbery and gun charges, Dist. Ct. erred in joining said prosecution with other bank robbery charges involving another defendant, even though govt. argued that other bank robberies were part of same series of acts or transactions. While all defendants need not be charged in every count, nor must they be charged with same crimes, instant indictment did not charge conspiracy or allege facts indicating that all defendants robbed banks as part of common plan or scheme. However, any error was harmless given strength of evidence against all defendants. Also, Dist. Ct. did not err in denying defendants’ request for mistrial even though one juror went to court’s chambers after jury rendered guilty verdicts and told staff member that she felt bullied into finding defendants guilty. Dist. Ct. was not required to question said juror about her claim, where there was no evidence either that said juror faced either outside pressure to change vote or threat of physical violence, or that said juror was incompetent to serve as juror.