Warger v. Shauers

Facts of the Case

Petitioner Gregory Warger was riding his motorcycle on a highway outside Rapid City, South Dakota, when a truck driven by respondent Randy Shauers struck him from behind. Warger claims he was stopped at the time of the accident, while Shauers claims that Warger suddenly pulled out in front of him. Regardless of the cause of the accident, no one disputes its tragic result: Warger sustained serious injuries that ultimately required the amputation of his left leg. Warger sued Shauers for negligence in Federal District Court. During jury selection, counsel for both parties conducted lengthy

Question

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?

CONCLUSION

Yes. Justice Sonia Sotomayor delivered the opinion for the unanimous Court, which held that a plain reading of Rule 606(b) precludes the use of juror testimony when a party is seeking a new trial on the basis of juror dishonesty during voir dire. Prior to Congress’ enactment of the rule, judicial precedent had established the inadmissibility of testimony of jury misconduct for the purpose of impeaching a verdict, and the legislative history of Rule 606(b) indicates that Congress intended the rule to apply broadly. The Court also held that the rule did not raise any issue of constitutionality because juror impartiality continued to be assured by either party’s ability to bring forward evidence of juror bias at any time before the verdict is rendered.

Case Information

  • Citation: 574 US 40 (2014)
  • Granted: Mar 3, 2014
  • Argued: Oct 8, 2014
  • Decided Dec 9, 2014