Jury Deliberations Not Always Sacred

SCOTUS ruling makes exception required for racial bias in state rules protecting jury deliberations

A recent U.S. Supreme Court ruling gives a Colorado man a chance for a new trial, but how far it will extend beyond that is unclear.

In Peña-Rodriguez v. Colorado, a 5-3 panel of justices found that normally sacrosanct jury deliberations can be legally scrutinized if tainted by the racial bias of jurors after a final verdict. State courts below consistently found the opposite, claiming protections for closed-door deliberations rises above Sixth Amendment claims invoked by the case. 

The Colorado Supreme Court ruled in May 2015 that a state evidentiary rule prevented Miguel Peña-Rodriguez, who was convicted of a mix of misdemeanors and a felony for sexual contact with two teenagers, from seeking a new trial because it bars a juror from testifying about deliberations.

Colorado Rule of Evidence 606(b), also referred to as the “no-impeachment rule” in court rulings, only allows exceptions for “extraneous prejudicial information” in deliberations or if outside influences affected the verdict.

To read this story and other complete articles featured in the March 13, 2017 print edition of Law Week Colorado, copies are available for purchase online.