Warger v. Shauers (2014)
- Docket
- 13-517
- Decided
- 2014-01-01
Summary
Question: Does Federal Rule of Evidence 606(b) bar the testimony of a juror regarding statements made during deliberations for the purpose of showing alleged dishonesty by a prospective juror during jury selection? Conclusion: Yes. Justice Sonia Sotomayor delivered the opinion for the unanimous Court, which held that a plain reading of Rule 606(b) precludes the use of juror testimony when a party is seeking a new trial on the basis of juror dishonesty during voir dire. Prior to Congress' enactment of the rule, judicial precedent had established the inadmissibility of testimony of jury misconduct for the purpose of impeaching a verdict, and the legislative history of Rule 606(b) indicates that Congress intended the rule to apply broadly. The Court also held that the rule did not raise any issue of constitutionality because juror impartiality continued to be assured by either party's ability to bring forward evidence of juror bias at any time before the verdict is rendered.