State v. Garcia-Ongay, 169 Idaho 1

Defendant Tomas Garcia-Ongay was convicted of lewd and lascivious conduct with a minor; after verdict the Elmore County Jury Commissioner reported a pretrial statement by Juror #9 that he hoped to be assigned a trial with a "Mexican" so he could "find them guilty" and that he hoped "Trump builds that wall."
The Jury Commissioner’s report was emailed to the district court and flagged concern about race-based intent to convict.
Garcia-Ongay moved for a new trial and, separately, requested permission to investigate/contact jurors post-verdict to determine whether racial animus tainted deliberations.
The district court denied both requests, applying the Seiber clear-and-convincing standard for new-trial juror-misconduct claims and concluding the pretrial, unsworn remark did not meet Peña-Rodriguez.
The Idaho Supreme Court held the district court applied the wrong standard for the request to contact jurors, concluded there was good cause to investigate under Hall, and remanded to allow an interview of Juror #9 and, in the district court’s discretion, contact of other jurors.
The Court clarified procedural sequence: Hall governs post-verdict juror contact (good cause), Seiber governs new-trial relief (clear and convincing prejudice), and Peña-Rodriguez provides a constitutional exception to the no-impeachment rule in certain race-based deliberation cases.

Issue	State's Argument	Garcia-Ongay's Argument	Held
Proper standard for post-verdict juror contact to investigate racial animus	District court was within discretion; Garcia-Ongay failed to show good cause (and briefing mixed standards)	Peña-Rodriguez permits inquiry; Hall good-cause standard should govern investigator access to jurors	Hall good-cause standard governs whether juror contact may be permitted; district court erred by applying Seiber instead
Abuse of discretion in denying investigation	Juror’s unsworn, pretrial comment months earlier and no voir dire admission or juror reports post-trial make investigation unnecessary	Jury Commissioner’s credible report plus racial targeting of defendant suffice to show good cause for investigation	Court finds abuse of discretion; good cause existed to investigate; remand to permit interview of Juror #9 and discretionary contact of other jurors

Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (Supreme Court recognized constitutional exception to no‑impeachment rule for clear race‑based statements in deliberations)
Hall v. State, 151 Idaho 42 (2011) (adopted good‑cause test for post‑verdict juror contact to investigate misconduct)
State v. Seiber, 117 Idaho 637 (Ct. App. 1989) (two‑part clear‑and‑convincing standard for new trial based on juror misconduct)
State v. Ish, 166 Idaho 492 (2020) (Equal Protection requires trials free from racial discrimination in jury processes)
Powers v. Ohio, 499 U.S. 400 (1991) (discusses the jury’s role as a check on wrongful state power)
Rose v. Mitchell, 443 U.S. 545 (1979) (racial discrimination is especially pernicious in administration of justice)