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Warger v. Shauers

Supreme Court of the United States · 2014 · Evidence
574 U.S. 40 (2014)
Updated
EvidenceFederal Rule of Evidence 606(b)Juror impeachmentVoir direFRE 606(b)anti-impeachment rulejuror testimonyjury deliberations

Facts

Warger was seriously injured in a collision between his motorcycle and Shauers' truck, and he sued Shauers for negligence in federal court. During voir dire, prospective juror Regina Whipple stated she could be fair and impartial and did not indicate any inability to award damages for pain and suffering or future medical expenses. After the jury returned a verdict for Shauers, another juror submitted an affidavit stating that during deliberations Whipple discussed a collision in which her daughter was at fault and said that if her daughter had been sued, it would have ruined her life. Warger argued this showed Whipple had lied during voir dire and sought a new trial.

Issue

Does Federal Rule of Evidence 606(b) bar a party from using one juror's affidavit about another juror's statements during deliberations to prove that the latter juror was dishonest during voir dire? Also, does the affidavit fall within Rule 606(b)(2)(A)'s exception for extraneous prejudicial information?

Rule

Rule 606(b) applies during any proceeding that is an inquiry into the validity of a verdict, including a postverdict motion for a new trial based on alleged juror dishonesty during voir dire. Evidence about statements made during deliberations is inadmissible for that purpose unless it fits an express exception, and a juror's personal experiences and views brought into deliberations are internal, not 'extraneous prejudicial information' under Rule 606(b)(2)(A).

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In a federal products-liability trial in St. Louis, Maya Benton lost after the jury returned a defense verdict. Two days later, juror Eli Navarro told Maya's lawyer that during deliberations the foreperson, Dana Pike, said she had concealed during voir dire that her brother had been ruined by a prior lawsuit and that she could never be neutral in civil damages cases.

Maya moves for a new trial and offers Eli's affidavit recounting Dana's deliberation-room statement to prove Dana lied during voir dire. How should the court rule?

Explanation. Rule 606(b) applies during any proceeding that is an inquiry into the validity of a verdict, including a postverdict motion for a new trial based on alleged voir dire dishonesty. An affidavit describing what a juror said during deliberations is therefore inadmissible for that purpose unless an express exception applies. A juror's own life experience and bias are internal matters, not extraneous prejudicial information.