Juror Testimony Regarding Racial Bias
Pena-Rodriguez v. Colorado15-606
Most states and the federal government have a rule of evidence generally prohibiting the introduction of juror testimony regarding statements made during deliberations when offered to challenge the jury’s verdict. Known colloquially as “no impeachment” rules, they are typically codified as Rule 606(b); in some states, they are a matter of common law.
The question presented is whether a no-impeachment rule constitutionally may bar evidence of racial bias offered to prove a violation of the Sixth Amendment right to an impartial jury.
DECISIONDecided March 6, 2017 HOLDING
Where a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule give way in order to permit the trial court to consider the evidence of the juror’s statement and any resulting denial of the jury trial guarantee.
KENNEDY, J., delivered the opinion of the Court, in which GINSBURG, BREYER, SOTOMAYOR, and KAGAN, JJ., joined. THOMAS, J., filed a dissenting opinion. ALITO, J., filed a dissenting opinion, in which ROBERTS, C. J., and THOMAS, J., joined.
ORAL ARGUMENTArgued October 11, 2016
CERTIORARI STAGEGranted April 4, 2016
Supreme Court of Colorado
Decided May 18, 2015
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|2016-10-09||Is Juror Testimony About Racial Bias During Jury Deliberations Admissible?||Certiorari Granted||go to coverage|