Tanner v. United States
Citation and Court
483 U.S. 107 (1987), Supreme Court of the United States
Facts
After Tanner was convicted of mail fraud and conspiracy, two jurors came forward and told defense counsel that several jurors had consumed alcohol, marijuana, and cocaine during the trial, including during recesses. Tanner moved for a new trial based on juror misconduct and sought to present juror testimony as evidence of the misconduct. The district court denied the motion.
Issue
Whether juror testimony about drug and alcohol use by jurors during trial is admissible to impeach a jury verdict under FRE 606(b).
Holding
The Supreme Court held that FRE 606(b) bars admission of juror testimony about juror misconduct occurring during deliberations or trial, including testimony about juror drug and alcohol use, because this falls within the prohibition on juror impeachment of verdicts.
Rule / Doctrine
FRE 606(b) provides that a juror may not testify about any statement made or incident that occurred during deliberations, the effect of anything on a juror’s vote, or any juror’s mental processes in reaching the verdict. This prohibition is broad and applies to testimony about juror misconduct such as substance abuse during trial. The rule protects verdict finality and juror privacy, and alternative mechanisms (such as court observation and voir dire) exist to address juror misconduct.
Significance
Tanner v. United States is the leading case interpreting the scope of FRE 606(b)‘s prohibition on juror testimony to impeach verdicts. It raised significant concerns about whether the rule adequately protects defendants’ rights when juries are demonstrably impaired, and later prompted the amendment of FRE 606(b) to create an exception for extraneous prejudicial information and outside influence.