Category Archives: Federal Rules of Evidence

The No-Impeachment Rule Concerning Jury Deliberations: Racial Bias Is Sufficient Reason To Breach The Sanctity Of The Juror Deliberations And Challenge The Basis Of The Verdict.

Pena-Rodriguez v. Colorado

Decided March 6, 2017

137 S.Ct. 855, 197 L.Ed.2d 107

The No-Impeachment Rule Concerning Jury Deliberations: Racial Bias Is Sufficient Reason To Breach The Sanctity Of The Juror Deliberations And Challenge The Basis Of The Verdict.

 

Issue: Whether an exception to the federal no-impeachment rule applies when a juror makes a statement indicating that he or she relied on racial stereotypes to convict a defendant.

Holding: When a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a 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.

Facts: Petitioner was convicted of unlawful sexual conduct and harassment by a Colorado jury.

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