How have courts interpreted Rule 606(b) on allegations of juror racism during deliberations?

14. For example, the court in Smith v. Brewer, 444 F.Supp. 482 (S.D. Iowa 1978), after concluding that Rule 606(b) applied to allegations of juror racism during deliberations, qualified that determination as follows: "Where . . . an offer of proof showed that there was a substantial likelihood that a criminal defendant was prejudiced by the influence of racial bias in the jury room, to ignore the evidence might very well offend fundamental fairness." Id. at 490.

14. For example, the court in Smith v. Brewer, 444 F.Supp. 482 (S.D. Iowa 1978), after concluding that Rule 606(b) applied to allegations of juror racism during deliberations, qualified that determination as follows: "Where . . . an offer of proof showed that there was a substantial likelihood that a criminal defendant was prejudiced by the influence of racial bias in the jury room, to ignore the evidence might very well offend fundamental fairness." Id. at 490.