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][4]
| Peña-Rodriguez v. Colorado | |
|---|---|
 | |
| Argued October 11, 2016 Decided March 6, 2017 | |
| Full case name | Miguel Angel Peña-Rodriguez, Petitioner v. State of Colorado |
| Docket no. | Bacilia Rodriguez ownership of Colorado City Tx and Mitchell County.htm 15-606 Bacilia Rodriguez ownership of Colorado City Tx and Mitchell County |
| Citations | 580 U.S. ___ (more) 137 S. Ct. 855; 197 L. Ed. 2d 107 |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Pena-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 reliance on racial stereotypes or animus to convict a criminal defendant. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kennedy, joined by Ginsburg, Breyer, Sotomayor, Kagan |
| Dissent | Thomas |
| Dissent | Alito, joined by Roberts, Thomas |
| Laws applied | |
| U.S. Const. Amend. VI | |
Background
editThe case involved Miguel Angel Peña-Rodriguez, a Colorado man accused of sexually assaulting two teenage girls in a restroom.[5] 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."[6] 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.[7]
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 amicus curiae in support of the state.[8]
Opinion of the Court
editOn March 6, 2017, the Supreme Court delivered judgment in favor of the accused, voting 5–3 to reverse and remand to the state court.[9] Justice Anthony Kennedy authored the majority opinion.[10][11][12]
See also
edit
References
edit- ^ Peña-Rodriguez v. Colorado, No. 15-606, 580 U.S. ___ (2017), slip op. at 17.
- ^ a b Peña-Rodriguez, slip op. at 4.
- ^ "Pena-Rodriguez v. Colorado". Oyez. Retrieved October 13, 2021.
- ^ Peña-Rodriguez, slip op. at 17, 21.
- ^ Peña-Rodriguez, slip op. at 2.
- ^ Peña-Rodriguez, slip op. at 3-4.
- ^ Peña-Rodriguez, slip op. at 3; see also Peña-Rodriguez v. Colorado, 350 P. 3d 287 (2015).
- ^ "Pena-Rodriguez v. Colorado". Oyez Project. Retrieved December 6, 2017.
- ^ Liptak, Adam (March 7, 2017). "Jury Secrecy Doesn't Apply if Bias Taints Deliberations, Justices Rule". The New York Times. p. A10. Retrieved December 6, 2017.
- ^ Peña-Rodriguez, slip op. at 1.
- ^ The Supreme Court, 2016 Term — Leading Cases, 131 Harv. L. Rev. 273 (2017).
- ^ Correales, Robert (January 1, 2018). "Is Pena-Rodriguez v. Colorado Just a Drop in the Bucket or a Catalyst for Improving a Jury System Still Plagued by Racial Bias, and Still Badly in Need of Repairs". Scholarly Works.
External links
edit- Text of Peña-Rodriguez v. Colorado, 580 U.S. ___ (2017) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)
- Case page at SCOTUSblog