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Golden Eagle Archery Inc. v. Jackson

Texas Rule of Civil Procedure 327(b) does not preclude juror testimony about improper contacts with individuals outside the jury, nor juror testimony about matters or statements not occurring during the course of the jury's deliberations.

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The full case caption appears at the end of this opinion.

The main issue in this case is whether procedural and evidentiary rules may constitutionally prohibit jurors from testifying post-verdict about statements made during deliberations, unless such statements concern outside influences. See Tex. R. Civ. P. 327(b); Tex. R. Civ. Evid. 606(b). Ronald Jackson obtained a verdict in a products liability case, but moved for a new trial on several grounds, including juror misconduct, juror bias, and the adequacy of the verdict. After a hearing, the trial court denied the motion. The court of appeals reversed and remanded for a new trial, holding that Texas Rule of Civil Procedure 327(b) denied Jackson his constitutional right to a fair and impartial jury trial because it prohibited him from proving jury misconduct during deliberations. 974 S.W.2d 952, 954. Because we conclude that the rule is constitutional, we reverse the court of appeals’s judgment and remand to that court to consider Jackson’s other points of error that the court of appeals did not reach.

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