U.S. v. Farmer

In prosecution on armed bank robbery and firearm charges that resulted in conviction for defendant, Dist. Ct. did not err in denying defendant’s motion for new trial based on allegations of juror misconduct, even though alternate juror stated in affidavit that other jurors made statements during prosecution’s case indicating that they had discussed evidence and had already decided defendant’s guilt. Rule 606(b)(1) precludes consideration about how pre-deliberation statements by jurors may have affected actual deliberation and verdicts, and Dist. Ct. could properly determine that instant allegations should not be deemed prejudicial to defendant’s case where: (1) allegations of misconduct did not concern external influence on jury; and (2) jury was properly instructed with respect to importance and gravity of group deliberations.