Duckworth, Warden v. Owen

Background

A man convicted in Indiana claimed a juror received an anonymous threatening phone call during his trial and later told other jurors. The trial judge interviewed the juror in private and found her able to be fair. The state courts refused to allow juror questioning aimed at undoing the verdict, relying on an Indiana rule that bars interrogating jurors to impeach a verdict. The prisoner later filed a federal petition asking a court to order a new hearing.

Reasoning

The main question was whether a federal court reviewing the prisoner’s claim should follow Indiana’s rule or the Federal Rules of Evidence. The Court of Appeals for the Seventh Circuit said federal habeas courts should apply the Federal Rules (including Rule 606(b)), which allow juror testimony about outside prejudicial information, and ordered an evidentiary hearing. The Supreme Court declined to review that ruling, issuing only a denial of the petition for further review and granting the prisoner leave to proceed without paying fees.

Real world impact

Because the Supreme Court refused to take the case, the Seventh Circuit’s approach remains unreviewed by this Court and will govern this prisoner’s case. The practical effect is that federal courts may hear juror testimony about outside threats in similar federal-review proceedings, at least in that circuit. This denial is not a full Supreme Court ruling on the merits of the underlying constitutional question and leaves room for later review.

Dissents or concurrances

Justice Rehnquist, joined by the Chief Justice, dissented, arguing the lower court improperly substituted federal evidence rules for state law and that the Court should have agreed to review the constitutional issue.