Legal Memorandum: Motion for New Trial in IA

Issue: Under Iowa law, can a court consider the affidavit of a jury member in considering a motion for new trial?

Area of Law: Litigation & Procedure
Keywords: Motion for a new trial; Jury deliberations; Affidavit
Jurisdiction: Iowa
Cited Cases: 422 N.W.2d 491; 440 N.W.2d 880; 545 N.W.2d 522
Cited Statutes: Iowa R. Evid. 5.606(b)
Date: 01/01/2015

For policy reasons, courts are cautious about inquiring into jury deliberations, and the use of affidavits related thereto is limited but not prohibited.  “The goal of limiting investigation into jury deliberations is to assure finality and prevent ‘what is intended to be private deliberation, [from becoming] the constant subject of public investigation; to the destruction of all frankness and freedom of discussion and conference.'”  Ryan v. Arneson, 422 N.W.2d 491, 494 (Iowa 1988) TA l "Ryan v. Arneson, 422 N.W.2d 491, 494 (Iowa 1988)" s "Ryan" c 1 .

Upon an inquiry into the validity of a verdict or indictment, jurors may not testify as to

any matter or statement occurring during the course of the jury’s deliberations or to the effect of anything upon that or any other juror’s mind or emotions as influencing the juror to assent to or dissent from the verdict or indictment or concerning the juror’s mental processes in connection therewith.

Iowa R. Evid. 5.606 TA s "5.606" (b) TA s "5.606(b)" .  This prohibition does not completely bar jurors from testifying on matters related to the validity of a verdict.  Iowa R. Evid. 5.606(b) TA l "Iowa R. Evid. 5.606(b)" s "606(b)" c 4 .  To the contrary, the Iowa Supreme Court has held that this “language does not suggest that juror testimony which aids in establishing that which was agreed upon by the jury is prohibited.”  Prendergast v. Smith Laboratories, Inc., 440 N.W.2d 880, 883 (Iowa 1989) TA l […]

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