ected a jury from a panel of prospective jurors whose names, addresses, ethnic backgrounds and religous affiliations remain unknown to either side. This unusual procedure, designed to protect jurors from outside influence and the fear of retaliation, has occasionally been used in New York federal courts since the trial of drug kingpin Leroy "Nicky" Barnes.1 Despite apparent benefits, critics assail anonymous juries both as an infringment of the sixth amendment guarantee of an impartial jury 2 and as a serious and unnecessary erosion of the presumption of innocence.3 Since many attorneys believe trials are frequently won or lost during jury selection,4 any procedure diminishing the role of counsel invites close scrutiny and criticism. Opponents of anonymous juries argue that the procedure restricts meaningful voir dire and thereby undermines the defendant's sixth amendment right to an impartial jury.5 Critics also claim that jurors interpret their anonymity as proof of the defendant's criminal proclivity, thereby subverting the presumption of innocence.6 Nevertheless, this paper argues that anonymous juries neither undermine the sixth amendment nor meaningfully dilute the presumption of innocence. Limited Voir Dire and the Peremptory Challenge Consistent with due process and the sixth amendment,7 the trial judge may refuse to ask prospective jurors any questions not reasonably calculated to expose biases or prejudices relevant to the case.8 Although addresses and group affilations may indicate significant potential for bias, attorneys do not have an unfettered right to this information in every case.9 Denying access to these facts may constrain an attorney's ability to assemble an ideal jury, but it violates no constitutional right. Although the Barnes court may have been on firm constitutional ground in rejecting the defendants' request for the ethnic and religous backgrounds and addresse...
