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Published by the Indiana Office of Court Services

Warger v. Shauers, No. 13–517, 574 U. S. ____ (2014).

December 11, 2014 Filed Under: Civil Tagged With: S. Sotomayor, SCOTUS

Sotomayor, J.
Federal Rule of Evidence 606(b) provides that certain juror testimony regarding what occurred in a jury room is inadmissible “[d]uring an inquiry into the validity of a verdict.” The question presented in this case is whether Rule 606(b) precludes a party seeking a new trial from using one juror’s affidavit of what another juror said in deliberations to demonstrate the other juror’s dishonesty during voir dire. We hold that it does.
….
We hold that Rule 606(b) applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire. In doing so, we simply accord Rule 606(b)’s terms their plain meaning. The Rule, after all, applies “[d]uring an inquiry into the validity of a verdict.” Rule 606(b)(1). A post verdict motion for a new trial on the ground of voir dire dishonesty plainly entails “an inquiry into the validity of [the] verdict”: If a juror was dishonest during voir dire and an honest response would have provided a valid basis to challenge that juror for cause, the verdict must be invalidated. See McDonough, 464 U. S., at 556.
This understanding of the text of Rule 606(b) is con­sistent with the underlying common-law rule on which it was based. Although some common-law courts would have permitted evidence of jury deliberations to be intro­duced to demonstrate juror dishonesty during voir dire, the majority would not, and the language of Rule 606(b) reflects Congress’ enactment of the more restrictive ver­sion of the common-law rule.
….
For the foregoing reasons, the judgment of the United States Court of Appeals for the Eighth Circuit is affirmed.
It is so ordered.
 

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