In the American legal system, jury deliberations are sacred. Jurors meet in secret, and their deliberations are largely shielded from scrutiny under the no-impeachment rule, which was codified in 1975 with Federal Rule of Evidence (FRE) 606(b).
With very limited exceptions, the no-impeachment rule prohibits jurors from testifying about almost anything that occurred during or impacted the deliberations. The purpose of this rule is to ensure candid debate among jurors and safeguard the finality of jury verdicts.
Nevertheless, this rule can make it difficult to challenge a tainted jury verdict, and courts have been reluctant to overturn verdicts on the basis of prejudicial or otherwise improper jury deliberations.
In the recent Supreme Court case of Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (2017), however, the Court changed course. Miguel Peña-Rodriguez was convicted of child molestation in Colorado. After the trial, jurors told defense counsel that one of the jurors had made racist comments about the defendant and a witness.
The trial court concluded that the juror did appear racially biased, but refused to grant a new trial based on Colorado Rule of Evidence 606(b), which mirrors FRE 606(b). Peña-Rodriguez challenged the decision, and a divided Supreme Court concluded that a juror’s reliance on racial animus in a conviction could be grounds to overturn a jury verdict.
If a juror’s bias resulted in the denial of a fair and impartial jury, the Court determined that the no-impeachment rule must give way to constitutional considerations of fairness and equality.
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