Peña-Rodriguez v. Colorado

Peña-Rodriguez v. Colorado, 580 U.S. ___ (2017), was a United States Supreme Court decision holding that the Sixth Amendment requires a racial bias exception to the no-impeachment rule.[1] According to two jurors, a third juror made a number of biased statements about the defendant's Mexican ethnicity, stating, "I think he did it because he’s Mexican and Mexican men take whatever they want."[2] In a 5–3 vote, the Court held that, notwithstanding a state evidentiary rule, the trial court must be permitted to consider the two jurors' testimony.[3]

Peña-Rodriguez v. Colorado
Argued October 11, 2016
Decided March 6, 2017
Full case nameMiguel Angel Peña-Rodriguez, Petitioner v. State of Colorado
Docket no.15-606
Citations580 U.S. ___ (more)
137 S. Ct. 855; 197 L. Ed. 2d 107
Opinion announcementOpinion announcement
Case history
PriorPena-Rodriguez v. People, 2015 CO 31, 350 P.3d 287; cert. granted, 136 S. Ct. 1513 (2016).
Holding
The Sixth Amendment requires an exception to the no-impeachment rule when a juror makes a clear statement indicating that he or she relied on racial stereotypes or animus to convict a criminal defendant.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityKennedy, joined by Ginsburg, Breyer, Sotomayor, Kagan
DissentThomas
DissentAlito, joined by Roberts, Thomas
Laws applied
U.S. Const. Amend. VI

Background

The case involved Miguel Angel Peña-Rodriguez, a Colorado man accused of sexually assaulting two teenage girls in a restroom.[4] During jury deliberations, Juror H.C. allegedly made a number of racially biased comments, stating, "Mexican men had a bravado that caused them to believe they could do whatever they wanted with women," and "nine times out of ten Mexican men were guilty of being aggressive toward women and young girls."[5] Juror H.C. also stated that the defendant's alibi witness was not credible because the witness was "an illegal."[2] The jury found Peña-Rodriguez guilty of unlawful sexual contact and harassment, but after the jury was discharged, two jurors, M.M. and L.T., remained to speak with defense counsel in private. Both signed affidavits describing H.C.'s remarks.[6]

On October 11, 2016, oral arguments were heard, where Professor Jeffrey L. Fisher appeared for the accused, the Colorado Solicitor General appeared for that state, and an assistant to the U.S. Solicitor General appeared as a friend in support of the state.[7]

Opinion of the Court

On March 6, 2017, the Supreme Court delivered judgment in favor of the accused, voting 5–3 to reverse and remand to the state court.[8] Justice Anthony Kennedy authored the majority opinion.[9][10]

See also

References
  1. Peña-Rodriguez v. Colorado, No. 15-606, 580 U.S. ___ (2017), slip op. at 17.
  2. Peña-Rodriguez, slip op. at 4.
  3. Peña-Rodriguez, slip op. at 17, 21.
  4. Peña-Rodriguez, slip op. at 2.
  5. Peña-Rodriguez, slip op. at 3-4.
  6. Peña-Rodriguez, slip op. at 3; see also Peña-Rodriguez v. Colorado, 350 P. 3d 287 (2015).
  7. "Pena-Rodriguez v. Colorado". Oyez Project. Retrieved 6 December 2017.
  8. Liptak, Adam (7 March 2017). "Jury Secrecy Doesn't Apply if Bias Taints Deliberations, Justices Rule". The New York Times. p. A10. Retrieved 6 December 2017.
  9. Peña-Rodriguez, slip op. at 1.
  10. The Supreme Court, 2016 Term — Leading Cases, 131 Harv. L. Rev. 273 (2017).
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