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In the case of Pena Rodriguez v. Colorado, a man named Peña Rodriguez had been convicted of sexual conduct and harassment in the Colorado Supreme Court. However, after the final verdict, it was brought to Peña Rodriguez’s attention by the other jurors that there had been a juror making racial bias statements against Peña Rodriguez and his witness which made it clear, his statements caused him to pinpoint Peña Rodriguez as guilty. This incident caused Peña Rodriguez to believe that he should be given a new trial, however by Colorado’s Rules of Evidence Rule 606(b) blocked Peña Rodriguez’s right to use statements made in jury deliberation. Pena-Rodriguez v. Colorado was then brought to the US Supreme Court where the judges argued whether or not the Rule 606(b) of Colorado’s Rules of Evidence allowing evidence of racial bias in the juror decision to be concealed was a violation against Peña Rodriguez’s Sixth Amendment right to an impartial jury.
Back in 2007 at Arapahoe Race Track, three teenage girls went into the bathroom where a man came in and asked them if they wanted to have a drink and party with him in which one girl left right before the man supposedly turned off the lights and began sexually assaulting the other two. After escaping and letting their father know, they named that the guy in the bathroom was Peña Rodriguez who worked at the track, but later had a witness who confirmed he was not at the track at the time of the assault. Eventually though, Peña Rodriguez was convicted of unlawful sexual conduct and harassment in the state trial court. However, after being called guilty, two jurors on his trial went to Peña Rodriguez’s counsel and claimed that during the trial, one of the other jurors had been making racially biased statements about him. The juror named H. C, a former law enforcement officer, was said to have said, “[he thought Peña Rodriguez] did it because he’s Mexican, and Mexican men take whatever they want,’” and according to another juror he said “that where he used to patrol, nine times out of 10 Mexican men were guilty of being aggressive toward women and young girls.”” Due to the juror’s obvious racial claims against Peña Rodriguez, Peña Rodriguez called for a new trial but the Colorado Supreme Court denied him, in favor of their Rule 606(b) which means one cannot introduce evidence regarding statements made in jury deliberations.
The Supreme Court of Colorado also claimed that Rule 606(b) did not violate Peña Rodriguez’s Sixth Amendment right to an impartial jury because Pena-Rodriguez had failed to question jurors about their racial bias beforehand. In the end, Peña Rodriguez believed that this rule can’t be used because it is a clear violation to his right to an impartial jury under the Sixth Amendment to the Constitution in which he believed only the U.S Supreme Court would be able to decide. The U. S Supreme Court called for a 5-3 decision in favor of Pena-Rodriguez, arguing that when a juror makes a clear statement suggesting that he or she relied on racial bias opinions, there is a violation against the Sixth Amendment. Rule 606(b) of Colorado’s Rules of Evidence can’t block evidence of clear racial bias statements that affects the final verdict of a case.
In the end, the U.S. Supreme Court reversed and remanded the judgment of the Colorado Supreme Court. Justice Anthony M. Kennedy called the opinion for the 5-3 majority explaining that if a juror makes a clear statement that they relied on racial statements to convict a criminal defendant, the court is permitted to consider evidence of their statements regarding the case. The Court ruled that Rule 606(b), the no-impeachment rule, was originally intended to prevent jurors from testifying about their thought process after a verdict was final. However, the Court agreed that there would be exceptions in special cases, including Peña Rodriguez’s case. In certain rare cases, when racial bias is obvious, the no-impeachment rule can’t be argued because of the Sixth Amendment. In addition, one might argue that there are processes that intend to prevent racial bias in juries (i.e voir dire), but these protections aren’t always successful, and therefore some exceptions are necessary. In this case of Peña Rodriguez, the Court held that the juror’s statements were indeed reliance on racial bias and even so the juror in question encouraged other jurors to join in his racially motivated conviction. Resultantly, the Colorado Supreme Court must review the juror’s statements against Peña Rodriguez. The dissenting opinion argued that the majority opinion falsely interpreted the Sixth Amendment and that the Sixth Amendment never allowed questioning of a final verdict. But even then, if there are reasons for limiting the no impeachment rules, it’s not up for court to decide whether is or is not allowed, but the political branches to decide. The dissenting opinion also argued that juror testimony has a long history and even though racial bias is important and should be prevent, it cannot be treated separately from other forms of impartiality by a juror for the sole purposes of a violation of the Sixth Amendment. The Sixth Amendment never set aside racial bias from other jury complications, therefore allowing this one case to be reversed and remanded is unfair to previous cases containing jury misconduct.
American law ultimately views the jury room as a secret, valued area in which the discussion that takes place in there is confidential so much that there is even a rule in which the final verdict can not be impeached based off something said or done from the jury room. Over the years, however, different exceptions and twists have been placed on this rule and for Peña Rodriguez’s case, the court’s decision shows how race can alter and challenge Constitutional laws. The Court’s decision that these statements from the jury can be used as evidence calls for a game changer, considering usually a verdict can only be impeached if there is evident something extreme may have affected the fairness of the trial (i.e a bribe or threat), not based off of what might have been said or done in a closed discussion after the final verdict was given. Usually cases including race discrimination connect back to the Equal Protection right, however there was no evident racial discrimination against Peña Rodriguez causing others to question the effect race has on laws. More so, it is clear the Court’s are slowly altering the American law based off of their ideas of what cases are more important and which cases are the “exceptions.”In the end, Peña Rodriguez’s argument that his right to an impartial jury was violated by a juror’s racist opinions was backed up by the Supreme Court.
The US Supreme Court ruled that Colorado’s Rules of Evidence Rule 606(b) can not interfere or hide evidence of racial bias from the jury which can be used as evidence to prove a violation of the Sixth Amendment. The Court’s decision of 5-3 in favor of Peña Rodriguez concluded that since the juror made it clear that they relied on racial bias to convict the defendant, the court can consider those statements as evidence which makes the impartial jury no longer valid according to the judges.
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