Pena-Rodriguez v. Colorado, 137 S. Ct. 855

Background

Miguel Angel Peña‑Rodriguez, a Hispanic defendant, was convicted by a Colorado jury for unlawful sexual contact and harassment; after discharge two jurors reported that another juror (H.C.) made racially prejudiced statements blaming Mexican men for sexual aggression.
Trial court, relying on Colorado Rule of Evidence 606(b) (modeled on Federal Rule 606(b)), excluded juror affidavits recounting deliberations and denied a new trial.
Colorado appellate courts affirmed; the Colorado Supreme Court held there was no constitutional exception to the no‑impeachment rule for racial bias.
The U.S. Supreme Court granted certiorari to decide whether the Sixth Amendment requires an exception to the no‑impeachment rule where juror statements show racial animus was a significant motivating factor in a guilty verdict.
The Court held that when a juror makes a clear statement showing reliance on racial stereotypes or animus that tends to show race was a significant motivating factor in a juror’s vote to convict, the Sixth Amendment permits inquiry and admission of such juror evidence despite the no‑impeachment rule.

Issues

Issue	Peña‑Rodriguez's Argument	Colorado / Respondent's Argument	Held
Whether the Sixth Amendment creates a constitutional exception to no‑impeachment rules for juror statements showing racial bias during deliberations	Juror affidavits showing clear racial animus that motivated a juror’s vote must be admissible so the court can determine whether the defendant’s right to an impartial jury was violated	The long‑standing no‑impeachment rule (Rule 606(b)) protects deliberation confidentiality and finality; racial bias does not create a constitutional exception	Yes. When there is a showing that a juror made a clear statement exhibiting racial bias that tended to show race was a significant motivating factor in a conviction, trial courts may consider juror testimony despite Rule 606(b)
Standard for opening inquiry into deliberations after a claim of racial bias	A low threshold: any credible allegation of racial statements should trigger inquiry	Maintain Rule 606(b)’s categorical bar except for extraneous influences; leave any change to legislatures or rulemakers	The trial court has substantial discretion; the proffer must show overt racial bias that casts serious doubt on fairness and that race was a significant motivating factor; courts assess content, timing, and reliability
Scope and remedies if bias is shown	Permit evidentiary inquiry and, if warranted, grant new trial or remedial relief	Admission would undermine jury confidentiality, encourage harassment, and destabilize verdicts	The Court did not prescribe specific procedures or a fixed standard for relief; it remanded for consideration consistent with the new constitutional rule
Interaction with rules limiting post‑trial juror contact and professional ethics	Counsel may obtain juror affidavits if jurors volunteer information; ethical/local rules govern post‑trial contacts	Such rules should bar or restrict post‑trial juror contact to protect juror privacy and deliberation secrecy	The Court recognized local ethics and court rules limit post‑trial contact but noted jurors may voluntarily come forward; mechanics governed by local rules and trial court discretion

Key Cases Cited

Tanner v. United States, 483 U.S. 107 (1987) (upheld no‑impeachment rule as consistent with Sixth Amendment where juror intoxication alleged)
McDonald v. Pless, 238 U.S. 264 (1915) (rejected receiving juror affidavits about deliberations; warned against undermining verdict finality)
Mattox v. United States, 146 U.S. 140 (1892) (permitted juror testimony where jury consulted extraneous prejudicial information)
Strauder v. West Virginia, 100 U.S. 303 (1880) (Fourteenth Amendment forbids exclusion of jurors on account of race)
Batson v. Kentucky, 476 U.S. 79 (1986) (prohibits race‑based peremptory strikes)
Turner v. Murray, 476 U.S. 28 (1986) (due process may require voir dire on racial prejudice in particular cases)
Hernandez v. Texas, 347 U.S. 475 (1954) (prohibits purposeful exclusion of jurors on account of ethnicity)