In King v. Bauer, 767 S.W.2d 197 (Tex. App.--Corpus Christi 1989, writ denied), the court held that the rules did not violate the open courts and due course of law guarantees afforded by the Texas Constitution, holding that the mere fact that the rules pose procedural difficulties to prove jury misconduct did not deprive the litigant of a remedy by due course of law. King, 767 S.W.2d at 199.