Peña-Rodriguez v. Colorado

After Miguel Peña-Rodriguez (defendant) was convicted, two jurors voluntarily approached defense counsel and reported that another juror, H.C., had made racist statements during deliberations demonstrating that racial animus motivated him to vote for conviction, and that H.C. had encouraged fellow jurors to convict for similar racially biased reasons; the trial court acknowledged the bias shown in H.C.'s comments but denied a new trial because Colorado's no-impeachment evidence rule (like the federal rule) generally barred using juror testimony about deliberations to challenge a verdict. Colorado's appellate courts affirmed, and the U.S. Supreme Court granted review.