The Sixth Amendment requires an exception to the “no-impeachment” rule for jury deliberations where a juror’s statements indicate that racial animus was a significant motivating factor in his or her finding of guilt. After a Colorado jury returned guilty verdicts against Pena-Rodriguez, two jurors approached his trial attorney to report that a third juror had made statements during deliberations reflecting that his guilty vote was the product of racial animus. The trial court denied Pena-Rodriguez’s motion for a new trial, citing the state’s no-impeachment rule, which generally prohibits a juror from testifying as to statements made during deliberations in a proceeding addressing the validity of the verdict. The state appellate courts upheld the ruling. The U.S. Supreme Court granted certiorari. Held: Reversed. Prior decisions concerning exceptions to the no-impeachment rule, the history of the Civil War Amendments, including their aim to eliminate racial animus in the justice system, the fact racial bias is a “familiar and recurring evil that, if left unaddressed, would risk systemic injury to the administration of justice,” and the insufficiency of other safeguards to protect against jurors with racial bias, all necessitate a racial bias exception to the no-impeachment rule. The exception provides that “where a juror makes a clear statement that indicates 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.” For the exception to apply, “there must be a showing that one or more jurors made statements exhibiting overt racial bias that cast serious doubt on the fairness and impartiality of the jury’s deliberations and resulting verdict. To qualify, the statement must tend to show that racial animus was a significant motivating factor in the juror’s vote to convict.” The state court’s judgment was reversed and the case was remanded.
The full opinion is available on the court’s website here: https://www.supremecourt.gov/opinions/16pdf/15-606_886b.pdf