SCOTUSblog: Warger v. Shauers
Background: Gregory Warger sued Randy Shauers for injuries he sustained during a traffic accident. The jury returned a verdict for Shauers. However, after the jury was released, one of the jurors contacted Warger's lawyer and expressed his concern as to the jury foreperson having behaved inappropriately during deliberations. Specifically, the juror alleged the foreperson had focused on her own daughter's past experience with a serious traffic accident, rather than the evidence presented at trial, In an affidavit, the juror contended that during deliberations the foreperson stated her daughter's life would have been ruined had her daughter been held liable for damages caused by the accident, and that she was unwilling to return a verdict for Warger because the Shauers were a young couple and their lives would also be ruined should they be found liable. Courts have held that juror testimony can be used to show dishonesty during voir dire for the purpose of contempt proceedings against the juror, but there is a split among the circuits as to whether such testimony may be used to challenge a verdict. The Eighth Circuit ruled that the juror's affidavit was not admissible under Federal Rule of Evidence 606(b), which prohibits inquiries into the validity of a verdict. Although Rule 606 provides three exceptions to the general rule prohibiting the admissibility of such evidence, the panel ruled that jurors' personal experiences do not meet the extraneous information exception.
Issue: The question before the Court was whether Federal Rule of Evidence 606(b) permits a party moving for a new trial based on juror dishonest during voir dire to introduce juror testimony about statements made during deliberations that tend to show the alleged dishonesty.
Holding: In a unanimous decision, the Supreme Court ruled that Rule 606(b) applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire because the plain meaning of Rule 606(b) applies to “an inquiry into the validity of [the] verdict.”