Lezmond Charles Mitchell v. United States
HabeasCorpus Punishment JusticiabilityDoctri
In Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (2017), this Court held, for the first time, that no-impeachment rules may not bar consideration of juror testimony showing a verdict was likely motivated by racial bias. In dissent, Justice Alito questioned whether there are "principled grounds for preventing the expansion" of Peña-Rodriguez and questioned whether local rules restricting post-verdict contact with jurors would survive this holding. The questions presented are:
1. Whether, after Peña-Rodriguez, district courts can validly bar death-sentenced inmates from interviewing trial jurors post-verdict concerning racial bias during deliberations?
2. Whether a change in decisional law such as Peña-Rodriguez is an "extraordinary circumstance" that justifies reopening under Federal Rule of Civil Procedure 60(b)(6)?
Whether district courts can validly bar death-sentenced inmates from interviewing trial jurors post-verdict concerning racial bias