Juror statements about jury selection
Warger v. Shauers
In brief
The Supreme Court agreed that Warger could not use a juror’s account of jury discussions to support his request for a new trial.
- Where it stands
- Decided
Decided 9-0 · December 9, 2014 · Opinion by Justice Sotomayor
- What it’s about
- Gregory Warger sought a new trial using one juror’s account of another juror’s statements during deliberations to argue that the juror had been dishonest during jury selection.
- Who it affects
- The appeals court’s decision to exclude the juror’s account remains in place, so Warger could not use it to support his request for a new trial.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the appeals court (affirmed) that Rule 606(b) barred the testimony because the statements were part of the jury’s internal deliberations.
Warger argued that juror Whipple would have been disqualified if she had disclosed her daughter’s accident during jury selection.
The case concerned whether a juror could testify about jury discussions to challenge another juror’s honesty during jury selection.
Question presented
Does Federal Rule of Evidence 606(b) bar the testimony of a juror regarding statements made during deliberations for the purpose of showing alleged dishonesty by a prospective juror during jury selection?
What the Court decided
Holding
Here, the excluded affidavit falls on the “internal” side. Warger contends that any information Whipple shared with the other jurors was extraneous because she would have been disqualified from the jury had she disclosed her daughter’s accident. However, such an exception would swallow up much of the rest of the restrictive version of the common-law rule that Congress adopted in enacting Rule 606(b). 721 F. 3d 606, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court treated Whipple’s statements to fellow jurors as part of the jury’s internal discussions, not information from outside the jury. It said treating information as outside the jury whenever it might have disqualified a juror would weaken much of Rule 606(b)’s limits.
The vote
What's next
The Supreme Court’s review is complete, and the appeals court’s ruling remains in place.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
Show 4 moreShow fewer
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Warger
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.