PENA-RODRIGUEZ v. COLORADO

MIGUEL ANGEL PENA-RODRIGUEZ, PETITIONER v. COLORADO
Supreme Court of the United States, Kennedy, March 6, 2017,
Jury Trial- A clear statement by a juror that they relied on racial bias to convict opens the conviction to examination by the courts.

(Dissent- Thomas – Not necessary to re-open the case under 6th or 14th)
(Dissent- Alito with Roberts and Thomas- Should keep the jury a black box)

What’s that shiny thing over there? A can of worms? Let’s open it!

Where a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant, the Sixth Amendment requires that the no-impeachment rule give way in order to permit the trial court to consider the evidence of the juror’s statement and any resulting denial of the jury trial guarantee.

Law from the Case
Jury Trial- In general, once a verdict has been entered courts are not allowed to examine how a jury made its decision.
Jury Trial – Racial Bias – Because racial bias is such a significant concern for the courts, they will make an exception and allow examination of jury verdict with clear evidence that they relied on improper racial bias.

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