Mattox v. United States
146 U.S. 140 (1892)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Juror testimony is inadmissible to impeach a verdict concerning matters that inhere in the verdict itself, such as a juror's thoughts or motivations, but is admissible to show the jury was exposed to extraneous, prejudicial information or outside influence.
Facts:
- Clyde Mattox was on trial for murder.
- During jury deliberations, which had lasted from one day to the next, a newspaper was introduced into the jury room.
- A juror read an article aloud which stated that Mattox had been tried for his life once before and that the evidence against him was very strong.
- The article also reported that the prosecution's argument was so convincing that Mattox's own friends had given up hope of any outcome other than conviction.
- A bailiff in charge of the jury also commented to the jurors that this was the third person Clyde Mattox had killed.
Procedural Posture:
- Clyde Mattox was convicted of murder in the District Court of the United States for the District of Kansas.
- Following the verdict, Mattox filed a motion for a new trial.
- In support of the motion, Mattox's counsel submitted affidavits from two jurors detailing prejudicial external communications from a bailiff and a newspaper article.
- The District Court refused to admit or consider the juror affidavits and denied the motion for a new trial.
- Mattox brought a writ of error to the Supreme Court of the United States to review the District Court's judgment.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
May juror affidavits be used to impeach a verdict by showing that the jury was exposed to prejudicial, external information not presented as evidence, such as a bailiff's comments or a newspaper article read during deliberations?
Opinions:
Majority - Mr. Chief Justice Fuller
Yes. Juror testimony is admissible to demonstrate that the jury was subjected to an extraneous influence. While public policy forbids receiving juror testimony about their internal deliberations or the personal consciousness of a juror, an exception exists for 'overt acts' of outside influence. These external influences, such as a bailiff's prejudicial comments or the introduction of a newspaper article containing information not in evidence, are accessible to the knowledge of all jurors and do not essentially inhere in the verdict itself. A juryman may testify to the existence of any extraneous influence, although not as to how that influence operated upon his mind. In a capital case, it is vital that the jury remain free from such external causes, and the statements from the bailiff and the newspaper were undeniably prejudicial and injurious to the defendant.
Analysis:
This case establishes a crucial exception to the general rule against jurors impeaching their own verdicts, often referred to as the Mansfield Rule. The Court draws a clear distinction between internal matters (a juror's thought processes, motives, or intra-jury discussions), which remain shielded, and external influences (newspapers, third-party communications), which can be testified to. This decision protects the finality of verdicts from being easily overturned by a single juror's second thoughts, while also safeguarding a defendant's Sixth Amendment right to a trial by an impartial jury whose verdict is based solely on evidence presented in court. It provides a procedural mechanism to investigate and remedy potential constitutional violations that occur within the sanctity of the jury room.
Unlock the full brief for Mattox v. United States