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650 KB
Extraction Summary
6
People
2
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
650 KB
Summary
This legal document is a page from a court filing, likely a judicial opinion or a party's brief, dated February 25, 2022. The text analyzes Federal Rule of Evidence 606, which prohibits jurors from testifying about their deliberations to challenge a verdict. The document discusses the rule's specific exceptions, such as external influence or racial bias, in the context of the Defendant's attempt to use statements from 'Juror 50' about what another juror said. The central issue is whether these statements are barred by Rule 606 or fall under one of its exceptions.
People (6)
| Name | Role | Context |
|---|---|---|
| Defendant | Defendant |
Mentioned throughout as the party making arguments to the court, relying on Juror 50's statements.
|
| Guzman Loera |
Cited in the case 'Guzman Loera, 24 F.4th at 161'.
|
|
| Moon |
Cited in the case 'Moon, 718 F.2d at 1234'.
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| Juror 50 | Juror |
A juror whose statements about another juror's comments during deliberations are being considered by the Court.
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| Pena-Rodriguez |
Cited in the case 'Pena-Rodriguez v. Colorado, 137 S. Ct. 855, 863 (2017)'.
|
|
| second juror | Juror |
A juror whose alleged statements during deliberations were reported by Juror 50.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
The judicial body being asked to consider juror statements and rule on their admissibility under Federal Rule of Evid...
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| Supreme Court | government agency |
Mentioned as having held that Rule 606 gives way in cases of racial bias.
|
Timeline (2 events)
Jury deliberations during which one juror allegedly made statements that were later reported by Juror 50.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the case name 'Pena-Rodriguez v. Colorado'.
|
Relationships (2)
The Defendant is making legal arguments to the Court regarding the admissibility of evidence.
Both were jurors in the same trial, and Juror 50 is reporting on statements allegedly made by the 'second juror' during their shared deliberations.
Key Quotes (4)
"haul [11] jurors in after they have reached a verdict"Source
— Court (quoting Moon)
(Describing what an evidentiary hearing would require, according to the Defendant's request.)
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Quote #1
"During an inquiry into the validity of a verdict or indictment, a juror may not testify about any statement made or incident that occurred during the jury’s deliberations; the effect of anything on that juror’s or another juror’s vote; or any juror’s mental processes concerning the verdict or indictment. The court may not receive a juror’s affidavit or evidence of a juror’s statement on these matters."Source
— Federal Rule of Evidence 606(b)(1)
(The text of the rule that generally bars juror testimony about deliberations.)
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Quote #2
"a juror makes a clear statement that indicates he or she relied on racial stereotypes or animus to convict a criminal defendant."Source
— Supreme Court (in Pena-Rodriguez v. Colorado)
(Describing an exception to Rule 606 where the rule 'give[s] way'.)
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Quote #3
"does not seek to impeach the verdict based on the"Source
— Defendant
(The Defendant's argument for why Juror 50's statements fall outside the scope of Rule 606.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,204 characters)
Case 22-1426, Document 78, 06/29/2023, 3536039, Page106 of 217
SA-360
Case 1:20-cr-00330-AJN Document 620 Filed 02/25/22 Page 12 of 21
SA-360
Case 1:20-cr-00330-AJN Document 620 Filed 02/25/22 Page 12 of 21
insufficient basis for an evidentiary hearing, especially one that, according to the Defendant,
would require the Court to “haul [11] jurors in after they have reached a verdict” to probe for
who, if anyone, may have been mentioned in the article. Guzman Loera, 24 F.4th at 161
(quoting Moon, 718 F.2d at 1234).
would require the Court to “haul [11] jurors in after they have reached a verdict” to probe for
who, if anyone, may have been mentioned in the article. Guzman Loera, 24 F.4th at 161
(quoting Moon, 718 F.2d at 1234).
Second, Federal Rule of Evidence 606 bars the Court from considering Juror 50’s
statements as evidence of another juror’s statements purportedly made during deliberations. As
previously quoted, the rule states:
statements as evidence of another juror’s statements purportedly made during deliberations. As
previously quoted, the rule states:
During an inquiry into the validity of a verdict or indictment, a juror may not
testify about any statement made or incident that occurred during the jury’s
deliberations; the effect of anything on that juror’s or another juror’s vote; or any
juror’s mental processes concerning the verdict or indictment. The court may not
receive a juror’s affidavit or evidence of a juror’s statement on these matters.
testify about any statement made or incident that occurred during the jury’s
deliberations; the effect of anything on that juror’s or another juror’s vote; or any
juror’s mental processes concerning the verdict or indictment. The court may not
receive a juror’s affidavit or evidence of a juror’s statement on these matters.
Fed. R. Evid. 606(b)(1).
Rule 606(b) is subject to three enumerated exceptions that permit a juror to testify about
whether (A) “extranous prejudicial information was improperly brought to the jury’s attention”;
(B) “an outside influence was improperly brought to bear on any juror”; or (C) “a mistake was
made in entering the verdict on the verdict form.” Fed. R. Evid. 606(b)(2). In addition to these
exceptions enumerated in the rule, the Supreme Court has held that Rule 606 “give[s] way”
where “a juror makes a clear statement that indicates he or she relied on racial stereotypes or
animus to convict a criminal defendant.” Pena-Rodriguez v. Colorado, 137 S. Ct. 855, 863
(2017). Absent one of these circumstances, evidence within the ambit of Rule 606 may not be
considered.
whether (A) “extranous prejudicial information was improperly brought to the jury’s attention”;
(B) “an outside influence was improperly brought to bear on any juror”; or (C) “a mistake was
made in entering the verdict on the verdict form.” Fed. R. Evid. 606(b)(2). In addition to these
exceptions enumerated in the rule, the Supreme Court has held that Rule 606 “give[s] way”
where “a juror makes a clear statement that indicates he or she relied on racial stereotypes or
animus to convict a criminal defendant.” Pena-Rodriguez v. Colorado, 137 S. Ct. 855, 863
(2017). Absent one of these circumstances, evidence within the ambit of Rule 606 may not be
considered.
Here, the Defendant relies on Juror 50’s statements of what another juror allegedly stated
during deliberations. That proffer is barred by Rule 606.
during deliberations. That proffer is barred by Rule 606.
In response, the Defendant argues that Juror 50’s statements about the second juror fall
outside the scope of Rule 606 because she “does not seek to impeach the verdict based on the
outside the scope of Rule 606 because she “does not seek to impeach the verdict based on the
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