Warger v. Shauers
United States Supreme Court
574 U.S. ___ (2014)
After a jury found for Shauers (defendant) in Warger's (plaintiff) negligence suit, a juror's affidavit revealed that another juror, Whipple, had stated during deliberations that her own daughter had caused a fatal car accident and that being sued over it would have ruined her life, despite Whipple's earlier voir dire assurance she could be impartial in a car-accident case; Warger sought a new trial based on the affidavit, and lower courts denied relief under FRE 606(b), leading to Supreme Court review.
Whether, under Federal Rule of Evidence 606(b), evidence of juror deliberations is admissible for a purpose other than proving an outside influence, extraneous information, or a mistake in the verdict.