In Golden Eagle Archery, Inc. v. Jackson, 24 S.W.3d 362, 364, 43 Tex. Sup. Ct. J. 989 (Tex. 2000), the issue presented was "whether procedural and evidentiary rules may constitutionally prohibit jurors from testifying post-verdict about statements made during deliberations, unless such statements concern outside influences." Jackson had sued Golden Eagle Archery and several other defendants for injuries he sustained while drawing back the string of a compound bow. Id. The jury found Jackson forty-five percent at fault for the injuries, and the trial court awarded Jackson approximately $ 26,700.00 in damages based on the jury's verdict. Id. Jackson filed a motion for new trial alleging juror misconduct and submitted affidavits from several jurors, the substance of which concerned statements made by several of the jurors during deliberations. Id. at 364-65. The trial court held the affidavits were incompetent under the civil rules of evidence and overruled Jackson's motion for new trial. Id. at 366. On petition for review, the Texas Supreme Court examined the various public policies in support of Rule 606(b), as well as the rule's foundation in Lord Mansfield's prohibition against post-verdict attacks via juror testimony. Id. at 367. The Golden Eagle court ultimately concluded, "While failure to disclose bias is a form of juror misconduct that justifies a new trial under the appropriate circumstances, proof of a juror's failure to disclose bias must come from some source other than a fellow juror's testimony about deliberations." Id. at 371. The Texas Supreme Court thus held: "Rules 327(b) and 606(b) do not deprive the litigants of a fair trial under the Texas Constitution, nor do they fail to afford litigants due process. The rules are designed to balance concerns about the threat of jury misconduct with the threat from post-verdict juror investigation and impeachment of verdicts." Id. at 375.