California, United States of America
The following excerpt is from People v. Cleveland, 106 Cal.Rptr.2d 313, 21 P.3d 1225, 25 Cal.4th 466 (Cal. 2001):
We held in People v. Hedgecock (1990) 51 Cal.3d 395, 418, 272 Cal.Rptr. 803, 795 P.2d 1260 that jurors could be compelled to testify at a postverdict evidentiary hearing regarding allegations of juror misconduct, but observed that "to avoid a chilling effect on the jury's deliberations, a trial court may decline to require jurors to testify when the testimony will relate primarily to the content of the jury deliberations." We stated: "In rare circumstances a statement by a juror during deliberations may itself be an act of misconduct, in which case evidence of that statement is admissible. [Citation.] But when a juror in the course of deliberations gives the reasons for his or her vote, the words are simply a verbal reflection of the juror's mental processes. Consideration of such a statement as evidence of those processes is barred by Evidence Code section 1150." (Id. at p. 419, 272 Cal.Rptr. 803, 795 P.2d 1260.)
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