The Seventh Circuit Court of Appeals has affirmed the conviction of Travis Thomas, ruling that the district court acted within its discretion both when it refused to question the entire jury pool after a prospective juror made comments suggesting deference to law enforcement charging decisions, and when it allowed the jury to deliberate with a redacted copy of the indictment.
The appeal centered on two key decisions made during jury selection and deliberation in Thomas’s 2019 sex trafficking trial. The defendant, Travis Thomas, argued that the entire pool of potential jurors (the venire) was tainted by remarks made by one individual, and that providing the jury with the indictment document during deliberations was prejudicial.
The Seventh Circuit found no reason to overturn the trial judge’s handling of the situation, concluding that the district court employed appropriate safeguards against potential bias.
The Controversial Juror Statement
The issue arose during voir dire (jury selection) when the district court was explaining the nature of an indictment—that it is merely a formal accusation and not evidence of guilt.
Prospective Juror 24, who had previously worked as a matron and file archivist for local government and law enforcement in Zion, Illinois, shared her perspective with the rest of the panel present. She stated that based on her experience, law enforcement agencies “wouldn’t usually bring anything that we didn’t have enough evidence to prosecute.” She further explained that if investigators in her former department didn’t have enough evidence, they simply wouldn’t proceed.
Although the prospective juror admitted this experience might affect her ability to remain impartial, the district court excused her “for cause.” However, the court refused Thomas’s motion to strike the entire remaining venire panel, arguing the comments had irreparably prejudiced the others.
Thomas contended that these statements—made in front of the entire panel—created an underlying belief among the other potential jurors that the government must have a strong case to even bring charges.
The Court’s Reasoning on Jury Impartiality
The Seventh Circuit, in an opinion authored by Judge St. Eve, emphasized that district courts have broad discretion in managing potential juror bias. The appellate court reviews these decisions only for an “abuse of discretion.”
The Seventh Circuit determined that the probability of bias infecting the remaining panel was low. First, the court noted that the prospective juror’s experience was limited to the Zion Police Department, which played no role in the investigation of Thomas’s case. While she mentioned socializing with members of other departments, including the Rockford Police Department (which was involved), the court found it unlikely her general comments would prevent the others from impartially evaluating the evidence.
Crucially, the appellate court pointed to the extensive curative measures taken by the district judge. The judge repeatedly instructed the entire venire—and later the seated jury—that an indictment carries no evidentiary weight and is not a sign of guilt. This instruction was given four times, including immediately after the controversial comments were made.
The Seventh Circuit relied on the established legal presumption that juries follow the judge’s instructions unless there is overwhelming evidence to the contrary. Given the limited connection of the juror’s experience to the actual case and the multiple judicial warnings, the appellate court found that the district court’s refusal to question or dismiss the remainder of the panel was a permissible exercise of judgment.
The court distinguished the current facts from past cases where bias was found, noting that in this instance, the judge’s decision was not based on logistical convenience but on a reasonable assessment of the low probability of actual prejudice.
The Redacted Indictment
Thomas also objected to the decision to provide the jury with a copy of the indictment during deliberations. While the indictment itself is a necessary charging document, defendants often argue it carries undue weight, especially when it contains formal language like being a “true bill.”
The district court provided the jury with a redacted version, removing extraneous language, and Thomas was found guilty on all five counts of sex trafficking and related charges after a four-day trial.
The Seventh Circuit found no error here either. Providing the indictment to the jury during deliberations is common practice in the Seventh Circuit, provided it is properly redacted and the jury receives proper instructions on its limited purpose. Since the court followed standard procedure and the indictment was deemed “bare-bones,” the decision was affirmed as well within the judge’s discretion.
Because the appellate court found no reversible error in either the handling of the potential juror bias or the provision of the indictment, Thomas’s claim of cumulative error also failed. The judgment of the district court was affirmed.