Pena-Rodriguez v. ColoradoAnnotate this Case
After entry of a guilty verdict, defense counsel obtained juror affidavits suggesting that one of the jurors exhibited racial bias against the defendant during deliberations. The trial court refused to consider these affidavits, finding that Colorado Rule of Evidence ("CRE") 606(b) barred their admission, and the court of appeals affirmed. The Supreme Court granted certiorari to consider whether CRE 606(b) applied to such affidavits and, if so, whether the Sixth Amendment nevertheless required their admission. After review, the Court concluded that the affidavits regarding the juror's biased statements fell within the broad sweep of CRE606(b) and that they did not satisfy the rule's "extraneous prejudicial information" exception. Furthermore, the Court held that the trial court's application of CRE 606(b) did not violate the defendant's Sixth Amendment right to an impartial jury. Accordingly, the Court affirmed the court of appeals' judgment.