August 18, 2019

Colorado Supreme Court: Protecting the Secrecy of Jury Deliberations is of Paramount Importance in Our Justice System

The Colorado Supreme Court issued its opinion in Pena-Rodriguez v. People on Monday, May 18, 2015.

Secrecy of Jury Deliberations—CRE 606(b)—Sixth Amendment Right to Impartial Jury.

After entry of a guilty verdict, defense counsel obtained juror affidavits suggesting that one of the jurors exhibited racial bias against defendant during deliberations. The Supreme Court granted certiorari to consider whether CRE 606(b) applies to such affidavits and, if so, whether the Sixth Amendment requires their admission. The Court held that the affidavits regarding the juror’s biased statements fall within the broad sweep of CRE 606(b) and that they do not satisfy the rule’s “extraneous prejudicial information” exception. The Court further held that the trial court’s application of CRE 606(b) did not violate defendant’s Sixth Amendment right to an impartial jury. Accordingly, the Court affirmed the judgment of the court of appeals.

Summary and full case available here, courtesy of The Colorado Lawyer.

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