Warger v. Shauers
Headline: Court bars use of juror deliberation affidavits to prove a juror lied during jury selection, upholding Rule 606(b) and making it harder for losing parties to get new trials based on juror statements.
Holding: The Court held that Rule 606(b) bars using one juror’s account of another juror’s deliberations to prove the other juror lied during jury selection, except for narrow exceptions for external influences or clerical mistakes.
- Prevents use of juror deliberation statements to prove juror lied during jury selection.
- Limits evidence available for post-trial challenges based on juror dishonesty.
- Affirms that jurors’ personal experiences are usually not treated as 'extraneous' evidence.
Summary
Background
A man injured when a truck hit his motorcycle sued the truck driver for negligence. During jury selection, a juror was asked whether she could be fair and said she could. After the jury returned a verdict for the driver, another juror signed an affidavit saying the foreperson had described a personal car crash involving her daughter and expressed strong negative feelings about people sued after accidents. The injured man asked for a new trial, arguing the foreperson had lied during jury selection about her impartiality.
Reasoning
The Court addressed whether Federal Rule of Evidence 606(b) allows one juror’s account of another juror’s statements made during deliberations to be used to prove that juror lied in jury selection. The Court said the Rule bars evidence about what happened in the jury room when a party is trying to challenge the verdict’s validity, except for narrow exceptions (external information, outside influence, or clerical mistakes). The Court explained that this reading follows the Rule’s plain language, its historical roots, and past decisions, and it rejected the idea that such deliberation evidence becomes allowed simply because it would show a juror should have been removed earlier.
Real world impact
The decision means parties cannot usually introduce jurors’ descriptions of deliberations to show a juror lied during jury selection. Lawyers must rely on evidence gathered before the verdict, non-juror evidence after trial, or the Rule’s narrow exceptions. This makes winning a new trial based on juror deliberation accounts more difficult.
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