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718 KB
Extraction Summary
5
People
2
Organizations
1
Locations
2
Events
2
Relationships
7
Quotes
Document Information
Type:
Legal document
File Size:
718 KB
Summary
This legal document page argues that Federal Rule of Evidence 606 bars the Court from considering statements made by Juror 50 about another juror's comments during deliberations. The text outlines the rule, its specific exceptions (such as extraneous information or racial animus), and concludes that the Defendant's attempt to introduce this evidence does not meet the criteria for any exception and is therefore inadmissible.
People (5)
| Name | Role | Context |
|---|---|---|
| Defendant | Defendant |
A party in the legal case, whose arguments are being discussed.
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| Guzman Loera |
Mentioned in a case citation: Guzman Loera, 24 F.4th at 161.
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| Moon |
Mentioned in a case citation: (quoting Moon, 718 F.2d at 1234).
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| Juror 50 | Juror |
A juror whose statements about another juror's comments are the subject of the legal argument.
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| Pena-Rodriguez |
Mentioned in a case citation: Pena-Rodriguez v. Colorado, 137 S. Ct. 855, 863 (2017).
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
The judicial body being addressed in the document.
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| Supreme Court | government agency |
Mentioned for having held that Rule 606 gives way in cases of racial animus.
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Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the case citation Pena-Rodriguez v. Colorado.
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Key Quotes (7)
"haul [11] jurors in after they have reached a verdict"Source
— Defendant
(Describing what the Defendant argues an evidentiary hearing would require.)
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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)
(Quoted text of the rule barring juror testimony about deliberations.)
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Quote #2
"extraneous prejudicial information was improperly brought to the jury’s attention"Source
— Federal Rule of Evidence 606(b)(2)
(An exception to the general rule, allowing a juror to testify.)
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Quote #3
"an outside influence was improperly brought to bear on any juror"Source
— Federal Rule of Evidence 606(b)(2)
(An exception to the general rule, allowing a juror to testify.)
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Quote #4
"a mistake was made in entering the verdict on the verdict form."Source
— Federal Rule of Evidence 606(b)(2)
(An exception to the general rule, allowing a juror to testify.)
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Quote #5
"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."Source
— Supreme Court
(A holding from the Supreme Court regarding an additional exception to Rule 606.)
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Quote #6
"does not seek to impeach the verdict based on the"Source
— Defendant
(Part of the Defendant's argument that Juror 50's statements fall outside the scope of Rule 606.)
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Quote #7
Full Extracted Text
Complete text extracted from the document (2,135 characters)
Case 1:20-cr-00330-PAE 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).
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:
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.
Fed. R. Evid. 606(b)(1).
Rule 606(b) is subject to three enumerated exceptions that permit a juror to testify about whether (A) “extraneous 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.
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
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