Warger v. Shauers
Headline: Court bars use of jurors’ deliberation statements to challenge verdicts, making it harder for parties to win new trials based on claims a juror lied during jury selection.
Holding: The Court held that Federal Rule of Evidence 606(b) bars juror testimony about statements made during deliberations—even when used to show a juror lied during jury selection—and the affidavit did not meet any Rule exceptions.
- Prevents using jurors’ deliberation statements to prove another juror lied at jury selection.
- Requires lawyers to rely on pre-verdict or non-juror evidence after trial.
- Keeps juror deliberations confidential and supports verdict finality.
Summary
Background
Gregory Warger, a man seriously injured in a motorcycle crash, sued the truck driver who hit him. After a jury returned a verdict for the driver, another juror told Warger’s lawyer that the jury foreperson had said during deliberations that her daughter once caused a fatal crash and that a lawsuit would have ruined her daughter’s life. Warger used that juror’s signed statement and asked for a new trial, saying the foreperson had lied during jury selection.
Reasoning
The Court addressed whether Federal Rule of Evidence 606(b) allows jurors’ statements about what was said in the jury room to be used to show a juror lied during selection. The Justices read the Rule’s plain language and its history and concluded the Rule bars evidence about statements made during deliberations in any proceeding that could invalidate a verdict. The Court rejected arguments that this statement was “extraneous” under the Rule’s exception, finding the foreperson’s personal experience was an internal matter, not external information.
Real world impact
The decision means parties generally cannot use a juror’s account of deliberations to challenge a verdict by alleging another juror lied during selection. Lawyers must rely on evidence gathered before the verdict or on non-juror evidence after trial. The ruling leaves other safeguards—questioning during selection and courtroom observations—to protect the right to a fair jury.
Dissents or concurrances
There were no separate dissenting or concurring opinions; the Court issued a unanimous opinion explaining its reading of Rule 606(b).
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