Your readers may be interested that on Dec. 9th the U.S. Supreme Court cited a 229-year-old decision by the great Lord Mansfield to support its holding that evidence of any statement made or incident that occurred during jury deliberations is inadmissible.
In Warger v. Shauers, No. 13-517, the losing party in a negligence action sought to introduce evidence by a juror that another juror had made statements during deliberations showing that she had lied during voir dire. Justice Sonia Sotomayor, for a unanimous court cited Vaise v. Delaval, 99 Eng. Rep. (1785), where Lord Mansfield held inadmissible an affidavit from two jurors claiming that the jury had decided the case through a game of chance.
