Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (2017)
After convicting Defendant-Petitioner Miguel Angel Peña-Rodriguez of unlawful sexual contact and harassment, two jurors told his attorney that another juror made racially disparaging remarks about the defendant and his alibi witness during the jury’s deliberations. Allegedly, the juror explicitly invoked stereotypes of Mexican men to justify his skepticism of the defendant’s alibi witness and belief that Peña-Rodriguez was guilty. Citing this juror’s explicit racial prejudices, Peña-Rodriguez filed a motion for a new trial. The U.S. Supreme Court eventually reviewed his case and found Peña-Rodriguez’s right to a fair trial outweighed society’s interest in preserving his conviction.
Writing for the majority, Justice Kennedy wrote that allowing racial prejudice to taint jurors’ deliberations impairs the jury system’s ability to serve as a check against government overreach. Furthermore, his opinion recognized racial bias as “a familiar and recurring evil that, if left unaddressed, would risk systemic injury to the administration of justice” because it implicates unique historical, constitutional, and institutional concerns. Peña-Rodriguez, 137 S.Ct. at 858. Kennedy also acknowledged the difficulty inherent in reporting another juror’s inappropriate racial comments, as most people react with outrage to accusations of bigotry. For these reasons, the Court found the Sixth Amendment requires trial courts to consider evidence that indicates racial animus or stereotypes informed a juror’s determination of guilt.