U.S. v. Torres-Chavez

In prosecution on drug conspiracy charges, Dist. Ct. did not err in refusing to consider post-verdict statements made by three jurors in subsequent voir dire proceedings in different case concerning their inability to follow court’s instructions regarding defendant’s failure to testify in his own defense. While all three jurors suggested that they viewed negatively defendant’s failure to testify on his behalf in spite of court’s prior instructions, said statements were inadmissible to establish any juror bias under Rule 606(b) because said statements touched upon jury’s internal deliberative processes, which fell within prohibition under Rule 606(b)(1). Moreover, although Rule 606(b)(2) contained three exceptions pertaining to outside influences that affect jury’s deliberations which would render juror’s statements admissible, instant statements did not fall within said exceptions.