Summary
U. S. Supreme Court case involving a long-standing rule of evidence that protects the secrecy of jury deliberations versus a criminal defendant’s constitutional right to an impartial jury. In May 2007, Miguel Pe’a-Rodriguez was arrested and charged with attempted sexual assault on a child, unlawful sexual contact, and harassment after an encounter with two teenage sisters in a bathroom where their father was employed. A three-day trial ensued. After entry of a guilty verdict, two jurors spoke with defense counsel alleging that a fellow juror made racially biased statements during deliberations. Pe’a-Rodriguez submitted affidavits from the two jurors and moved for a new trial. The trial court denied the motion, finding that Colorado Rule of Evidence 606(b) barred any inquiry into jury deliberations. The Colorado Court of Appeals and Colorado Supreme Court both affirmed the trial court’s decision. CJLF joined the case to argue that preserving the secrecy of jury deliberations is consistent with the right to a jury trial guaranteed by the Sixth Amendment and that allowing litigants to peek into the jury room under the guise of determining whether racial bias played a role in the decision-making process is contrary to Congressional intent and U. S. Supreme Court precedent. CJLF also argued that protecting the confidentiality of jury deliberations is fundamental to the uninhibited and forthright discussion that must occur for a jury to wholly focus on reaching the right result. The court created a narrow exception for racial bias claims and reversed the judgment, but it otherwise left the confidentiality rule in place.
