Lower Court Holding in Peña-Rodriguez v. Colorado
Decision of the Supreme Court of Colorado
This case involves the interplay between two fundamental tenets of the justice system: protecting the secrecy of jury deliberations and ensuring a defendant’s constitutional right to an impartial jury. After entry of a guilty verdict, defense counsel obtained juror affidavits suggesting that one of the jurors exhibited racial bias against the defendant during deliberations. The trial court refused to consider these affidavits, finding that Colorado Rule of Evidence (CRE) 606(b) (preventing inquiry into bias during jury deliberations) barred their admission, and the court of appeals affirmed. We granted certiorari to consider whether CRE 606(b) applies to such affidavits and, if…
