Pena-Rodriguez v. Colorado

Whether "no-impeachment" rules (generally prohibiting juror testimony regarding statements made during jury deliberations to challenge the jury's verdict) bar evidence of racial bias during jury deliberations, and if so, whether the constitutional right to a fair trial requires admission.

Petitioner, a Hispanic male, was charged with four sex crimes. During voir dire, none of the potential jurors' answers reflected a racial bias. After the jury found the Petitioner guilty on three counts, two jurors told Petitioner's counsel that a juror had made racially biased statements during deliberations and had used his experience as an ex-law enforcement officer to establish that "Mexican men" are prone to aggressive behavior toward women, and that the alibi witness was not credible because he was "an illegal." Affidavits from the two jurors were obtained and presented to the trial court with a request for a new trial. The trial court barred admission of the jurors' affidavits and Petitioner appealed. The Court of Appeals, in a split decision, affirmed the trial court. The Colorado Supreme Court affirmed. Rehearing was denied. Petitioner argues that the jury deliberations were corrupted by racial bias and is entitled to a new trial because the Sixth Amendment provides the right to an impartial jury. Respondent argues that authorizing post-verdict investigations of jurors compromises the jury process and would "seriously disrupt the finality" of the jury's verdict.