Civil Procedure — Juror bias

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U.S. Supreme Court

Civil

Civil Procedure — Juror bias

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.

This reading accords with the plain meaning of Rule 606(b),which applies to “an inquiry into the validity of [the] verdict.” This understanding is also consistent with the underlying common-law rule on which Congress based Rule 606(b). The so-called “federal rule” made jury deliberations evidence inadmissible even if used to demonstrate dishonesty during voir dire. Both the majority of courts and this Court’s pre-Rule606(b) cases, see McDonald v. Pless, 238 U. S. 264, 268; Clark v. United States, 289 U. S. 1, favored this rule over the “Iowa rule,” which permitted the use of such jury deliberations evidence. The federal approach is clearly reflected in the language Congress chose when it enacted Rule 606(b), and legislative history confirms that Congress’ choice was no accident. See Tanner v. United States, 483 U. S. 107, 125.

721 F. 3d 606, affirmed.

13-517 Warger v. Shavers

Sotomayor, J.

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