Warger v. Shauers
135 S. Ct. 521, 2014 U.S. LEXIS 8294, 190 L. Ed. 2d 422 (2014)
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Rule of Law:
Federal Rule of Evidence 606(b) precludes using juror testimony about statements made during deliberations to challenge a verdict, even when the testimony is offered to show that another juror was dishonest during voir dire.
Facts:
- Gregory Warger was seriously injured, resulting in the amputation of his left leg, when his motorcycle was struck from behind by a truck driven by Randy Shauers.
- During jury selection (voir dire) for Warger's negligence lawsuit, prospective juror Regina Whipple was asked if she could be a fair and impartial juror and if she could award damages for pain and suffering.
- Whipple answered that she could be fair and impartial.
- The jury, with Whipple serving as the foreperson, returned a verdict in favor of Shauers.
- After the trial, another juror contacted Warger's counsel.
- This juror provided an affidavit stating that during deliberations, Whipple had disclosed that her own daughter had been at fault in a fatal motor vehicle accident and commented that a lawsuit would have ruined her daughter's life.
Procedural Posture:
- Gregory Warger sued Randy Shauers for negligence in the U.S. District Court.
- A jury returned a verdict in favor of Shauers.
- Warger moved for a new trial, arguing juror misconduct and submitting an affidavit from another juror as evidence.
- The District Court denied the motion, holding that Federal Rule of Evidence 606(b) barred admission of the juror's affidavit.
- Warger, as appellant, appealed to the U.S. Court of Appeals for the Eighth Circuit.
- The Eighth Circuit affirmed the District Court's ruling, siding with appellee Shauers.
- The U.S. Supreme Court granted Warger's petition for a writ of certiorari.
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Issue:
Does Federal Rule of Evidence 606(b) bar a juror's affidavit about statements made during deliberations when it is offered to show that another juror made dishonest statements during voir dire?
Opinions:
Majority - Justice Sotomayor
Yes. Rule 606(b) applies to juror testimony during a proceeding in which a party seeks a new trial on the ground that a juror lied during voir dire. The plain text of the Rule applies to any 'inquiry into the validity of a verdict,' which includes a motion for a new trial based on juror dishonesty. This interpretation is consistent with the common-law 'federal rule,' which Congress adopted over the more lenient 'Iowa rule,' prohibiting the use of deliberations evidence unless it showed an extraneous influence. The Court rejected arguments that this inquiry is not about the verdict's validity and that excluding such evidence raises constitutional concerns about the right to an impartial jury, citing Tanner v. United States, which held that other safeguards like voir dire and non-juror evidence adequately protect this right. Furthermore, the juror's statements about her daughter are not 'extraneous prejudicial information' under the Rule's exception, as they constitute the juror's internal experiences and views, not external information specific to the case.
Analysis:
This decision firmly establishes the primacy of jury secrecy and verdict finality under Federal Rule of Evidence 606(b). It resolves a circuit split by adopting a strict interpretation of the rule, effectively closing a potential pathway for challenging verdicts based on juror bias that only becomes evident during deliberations. The ruling reinforces that the primary mechanisms for ensuring juror impartiality are the voir dire process, observations of juror behavior during trial, and the use of non-juror evidence of misconduct. Consequently, it places a higher burden on litigants to uncover potential bias before a verdict is rendered, as post-verdict impeachment based on what was said in the jury room is now broadly prohibited.
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