What is the test for admissible juror declarations that pertain to statements made or conduct that occurred in the jury room?

California, United States of America


The following excerpt is from The People v. Davis, A120428, No. 190226 (Cal. App. 2010):

6. Portions of the juror declarations that pertained to statements made or conduct that occurred in the jury room were admissible under Evidence Code section 1150, subdivision (a). Those statements "are evidence of objectively ascertainable overt acts that are open to sight, hearing, and the other senses and are therefore subject to corroboration." (People v. Steele (2002) 27 Cal.4th 1230, 1259-1267 (Steele))

7. For privacy sake, we will refer to jurors by their initials rather than their names.

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