Tanner v. United States, 483 U.S. 107 (1987), was a United States Supreme Court case in which the Court held that juror testimony could not be used to discredit or overturn a jury verdict, even if the jury had been consuming copious amounts of alcohol, marijuana, and cocaine throughout the course of the trial.
Background After the defendant was found guilty of mail fraud, his attorneys filed several motions after learning that seven of the jurors had consumed alcohol during the trial's noon recesses. Four of the jurors had consumed, between them "a pitcher to three pitchers" of beer during various recesses.Tanner v. United States, 483 U.S. 107, 115 (1987). Of the other three, one juror reported that he had observed two jurors drinking one or two mixed drinks on several occasions during lunch recess, while another juror, the foreperson, had consumed liter of wine on each of three occasions.483 U.S. at 115–116
The attorneys also uncovered evidence of drug use among the jurors. Juror Hardy testified that he and three other jurors smoked marijuana regularly throughout the trial. He also said that he had seen one juror use cocaine five times, and another use it two or three times. One juror sold of marijuana to another juror during the trial, and brought marijuana, cocaine, and drug paraphernalia into the courthouse. Hardy also recalled one juror describing himself as "flying".483 U.S. at 116
Opinion of the Court The court held that under Federal Rule of Evidence 606(b), the lower courts were correct in denying a hearing on juror misconduct.483 U.S. at 122 The court noted that "the near-universal and firmly established common-law rule in the United States flatly prohibited the admission of juror testimony to impeach a jury verdict".See 8 J. Wigmore, Evidence § 2352, pp. 696-697 (J. McNaughton rev. ed.1961)
See also No-impeachment rule Stambovsky v. Ackley Mattel, Inc. v. MCA Records, Inc.
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