The SCT has agreed to hear the case of Pena Rodriguez v. Colorado. The issue in Pena Rodriguez is whether a no-impeachment rule constitutionally may bar evidence of racial bias offered to prove a violation of the Sixth Amendment right to an impartial jury. This case can best be summed up by the prior Colorado Supreme Court opinion which found in favor of the state and affirmed the defendant's conviction. The first two paragraphs of the opinion are excerpted below.
This case involves the interplay between two fundamental tenets of the justice system: protecting the secrecy of jury deliberations and ensuring a defendant’s constitutional right to an impartial jury. 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. People v. Pena-Rodriguez, 2012 COA 193, ¶ 3, __ P.3d __. We granted certiorari to consider whether CRE 606(b) applies to such affidavits and, if so, whether the Sixth Amendment nevertheless requires their admission.1
¶2 We hold that the affidavits regarding the juror’s biased statements fall within the broad sweep of CRE 606(b) and that they do not satisfy the rule’s “extraneous prejudicial information” exception. We further hold that the trial court’s application of CRE 606(b) did not violate the defendant’s Sixth Amendment right to an impartial jury. Accordingly, we affirm the judgment of the court of appeals.