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.