This comment explores ways in which racial bias undermines the American jury system and argues that simply having a racial bias exception to the no-impeachment rule does not go far enough to guard against racially motivated jury verdicts. In order to guarantee the Sixth Amendment right to an impartial jury, defendants must always be able to question potential jurors about racial bias, and universal court policies need to be adopted across the country that allow for a consistent approach for investigating claims of racial bias in jury deliberations. Part I of this comment examines the history of American juries and the inception of the no-impeachment rule. Part II discusses the background that led to the Peiia-Rodriguez decision, while Part III dissects the Court's decision of the case. Part IV argues that the exception created by the Court in Peha-Rodriguez does not go far enough to guard against racial biases in jury deliberations and proposes policy changes that would allow for incidents of racial bias to be addressed prior to the issuing of a verdict. Finally, Part V concludes this comment by reiterating the importance of having an impartial jury that is free from racial bias.

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