Can a jury's subjective reasoning be used to challenge a verdict?

California, United States of America

The following excerpt is from People v. Johnson, F073002 (Cal. App. 2018):

^4. Pursuant to Evidence Code section 1150, subdivision (a), no evidence is admissible in challenging the validity of a verdict if it shows the effect of a statement or event on a deliberating juror or the mental processes by which the verdict was determined. (See People v. Cissna (2010) 182 Cal.App.4th 1105, 1116 [a juror's subjective reasoning is inadmissible to challenge a verdict].) We note that portions of the jurors' testimony elicited at the evidentiary hearing also violated this statute but neither party objected to the jurors' testimony on this basis.

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