Impeaching a Jury Verdict for Alleged Juror Misconduct After 9 Years

In Massey v. State, 541 A.2d 1254 (Del. 1988), the defendant tried to impeach a jury verdict for alleged juror misconduct more than nine years after the verdict was rendered. After several postconviction relief motions and appeals, the trial court held an evidentiary hearing on the defendant's juror misconduct claim. At the evidentiary hearing, the complaining juror testified and the trial court admitted the deposition testimony of nine jurors. See id. at 1255.Cf. Ex parte Greenville News, 326 S.C. 1, 482 S.E.2d 556, 557 (S.C. 1997) (noting that trial court permitted depositions of jurors relating to juror misconduct claim raised three years after conviction and death sentence were affirmed, founded on information received in anonymous phone call to defense counsel).