Evidence

Tanner v. United States — Study Notes

483 U.S. 107 (U.S. Supreme Court 1987)

Study notes for Tanner v. United States: professor notes, cold call prep, exam angles, and memory aids.

Federal Rule of Evidence 606(b) bars juror testimony about internal deliberations, including drug or alcohol use, to maintain jury integrity.
Professor Notes

In Tanner v. United States, the Supreme Court addressed the balance between the integrity of jury deliberations and the evidentiary rules guiding juror conduct post-verdict. The Court emphasized that allowing jurors to testify about their own internal deliberations, including drug and alcohol use, would undermine the sanctity and integrity of the jury process. Professors will likely stress the importance of Federal Rule of Evidence 606(b), noting it serves to prevent juror testimony regarding influences on their decisions that arise from internal deliberations, as opposed to external factors.

Furthermore, the Court's decision reinforces the idea that the Sixth Amendment does not impose an obligation on courts to provide jurors with an avenue to contest their verdict based on personal misconduct. This case illustrates a critical intersection of evidentiary rules and constitutional rights, showing the Court's commitment to preserving the jury's role in the justice system while simultaneously upholding procedural regularity and finality in verdicts.

Cold Call Prep
  1. 1Explain the significance of Federal Rule of Evidence 606(b) in Tanner v. United States.
  2. 2What was the Court's rationale for not allowing juror testimony related to intoxication?
  3. 3How did the Court interpret the limits of the Sixth Amendment in this case?
  4. 4What is the broader impact of Tanner v. United States on the principles of jury finality?
  5. 5Discuss how internal juror misconduct is treated under evidentiary rules.
  6. 6What arguments did the dissenting opinion present, if any?
  7. 7How might this case affect future litigation involving juror misconduct?
Mnemonic Device

Juries Must Remain Sober (JMSR)

Distinguish From
CaseDistinction
McDonough Power Equipment, Inc. v. GreenwoodMcDonough involved juror dishonesty regarding pre-existing biases, which is treated as an external influence, unlike internal misconduct in Tanner.
Parker v. GladdenParker dealt with juror bias from external sources, while Tanner focuses on internal jury conduct.
Policy Arguments

For the Rule

Maintaining the sanctity and finality of jury verdicts is essential for the integrity of the judicial process, preventing endless challenges based on juror’s internal experiences.

Against the Rule

Excluding evidence of juror intoxication can lead to unfair verdicts, as the legitimacy of the jury's decision-making may be compromised by their inability to function properly.

Class Discussion Points
  • Should there be exceptions to Rule 606(b) for extreme cases of juror misconduct?
  • What are the implications of this ruling for jurors who engage in misconduct due to substance abuse?
  • How do we ensure jurors are aware of their responsibilities regarding sober deliberation?
Exam Angle

Students should be prepared for essay questions that explore the tension between jury secrecy and individual rights, particularly focusing on Rule 606(b) and its limitations. This case may also appear in a multiple-choice format regarding evidential rules.

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