California, United States of America
The following excerpt is from Putensen v. Clay Adams, Inc., 12 Cal.App.3d 1062, 91 Cal.Rptr. 319 (Cal. App. 1970):
The only showing of prejudice attempted by plaintiff is through the jurors' affidavits aforementioned. Affidavits of jurors may be used to impeach their verdict only in certain limited situations. Such affidavits may be used to show that the verdict was reached by lot or chance and to show that one or more of the jurors concealed bias or prejudice on voir dire. (People v. Hutchinson, 71 Cal.2d 342, 346--348, 78 Cal.Rptr. 196, 455 P.2d 132.) They may also be used to impeach a verdict under the circumstances provided for in section 1150 of the Evidence Code. That section provides in subdivision (a) thereof as follows: 'Upon an inquiry as to the validity of a verdict, any otherwise admissible evidence may be received as to statements made, or conduct, conditions, or events occurring, either within or without the jury room, of such a character as is likely to have influenced the verdict improperly. No evidence is admissible to show the effect of such statement, conduct, condition, or event upon a juror either in influencing him to assent to or dissent from the verdict or concerning the mental processes by which it was determined.' (See People v. Hutchinson, supra, at p. 349, 78 Cal.Rptr. 196, 455 P.2d 132.)
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