This week the U.S. Supreme Court decided Peña Rodriguez v. Colorado. The decision on juror impeachment will change the law as it currently exist in Pennsylvania.
Some version of the no-impeachment rule is followed in every State and the District of Columbia. Variations make classification imprecise, but, as a general matter, it appears that 42 jurisdictions follow the Federal Rule, while 9 follow the Iowa Rule.
Within both classifications there is a diversity of approaches. Nine jurisdictions that follow the Federal Rule have codified exceptions other than those listed in Federal Rule 606(b).
At least 16 jurisdictions, 11 of which follow the Federal Rule, have recognized an exception to the no-impeachment bar under the circumstances the Court faces here: juror testimony that racial bias played a part in deliberations. Only one State other than Colorado has addressed this issue and declined to recognize an exception for racial bias, Pennsylvania. Commonwealth v. Steele, 599 Pa. 341, 377–379, 961 A.2d 786, 807–808 (2012).