Warger v. Shauers, 135 S. Ct. 521

Gregory Warger was seriously injured in a motorcycle‑truck collision and sued Randy Shauers for negligence; a federal jury returned a verdict for Shauers.
During voir dire, prospective juror Regina Whipple (later foreperson) denied any inability to be impartial or to award damages; the jury was seated including Whipple.
After verdict, a juror submitted an affidavit alleging Whipple described a personal family crash during deliberations, suggesting bias rooted in her daughter’s accident.
Warger moved for a new trial under McDonough, arguing Whipple lied on voir dire and that an honest answer would have supported a challenge for cause; the district court excluded the juror affidavit under Federal Rule of Evidence 606(b).
The Eighth Circuit affirmed; the Supreme Court granted certiorari and affirmed, holding Rule 606(b) bars juror testimony about deliberations to prove voir‑dire dishonesty and that the affidavit did not fit the Rule’s extraneous‑information exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 606(b) bars juror testimony about another juror’s statements in deliberations to show that juror lied on voir dire	Warger: Rule 606(b) does not apply because a McDonough motion focuses on voir dire dishonesty (not an inquiry into how the jury reached its verdict) and need not show effect on the verdict	Shauers: Rule 606(b) applies to any postverdict proceeding that may invalidate a verdict, so deliberation statements are inadmissible absent an exception	Court: Rule 606(b) applies; a new‑trial motion for voir‑dire dishonesty is an “inquiry into the validity of the verdict,” so juror deliberation statements are barred
Whether the juror affidavit falls within Rule 606(b)(2)(A)’s “extraneous prejudicial information” exception	Warger: Whipple’s deliberation statements should be treated as extraneous because she would have been disqualified and thus anything she said was outside the jury’s proper deliberative inputs	Shauers: Whipple’s daughter’s accident is internal (a juror’s life experience), not external case‑specific information; allowing this exception would swallow Rule 606(b)	Court: The affidavit was internal, not extraneous; the exception does not render admissible statements of a juror’s personal experiences during deliberations

McDonough Power Equip. v. Greenwood, 464 U.S. 548 (1984) (party may obtain new trial when a juror lied on voir dire and correct answer would have supported a for‑cause challenge)
Tanner v. United States, 483 U.S. 107 (1987) (Rule 606(b) bars juror testimony about deliberations; intoxication evidence excluded; extraneous vs internal distinction)
McDonald v. Pless, 238 U.S. 264 (1915) (rejected admitting juror affidavits to impeach verdict; emphasized finality and protection from tampering)
Clark v. United States, 289 U.S. 1 (1933) (admission of juror testimony in a prosecution unrelated to impeaching the prior verdict; clarified scope of the anti‑impeachment rule)
Hyde v. United States, 225 U.S. 347 (1912) (discussed limitations on juror testimony to impeach verdict)
Mattox v. United States, 146 U.S. 140 (1892) (addressed juror testimony and limits on impeachment of verdict)