Warger v Shauers

Warner sought to challenge a verdict in Shauers’ favor relying an affidavit from a juror that another juror lied during voir dire. The district court denied the motion and the 8th Circuit affirmed based on Federal Rule of Evidence 606(b). Resolving a circuit split on whether or not 606(b) bars juror evidence that another juror lied during voir dire, the Court unanimously held that such evidence is barred and thus affirmed. It held that under the plain language of 606(b), Congress adopted the broader common law rule which bars not only attacks on the process of decision-making but challenges to juror eligibility and veracity during voir dire. It held that 606(b) applies because seeing to overturn the verdict based on the lies amounts to challenge to the validity of the verdict and thus squarely within the language of the rule. The Court finally noted that juror experiences are internal to the jury process not extraneous and the extraneous prejudicial information exception did not apply.

Integrity Staffing Solutions, Inc. v Busk

Busk sued for back wages arguing that Integrity was required to pay for security screenings of its workers conducted after their shifts were done. The district court dismissed, but, the 9th Circuit reversed on the ground that the screenings were required. The Court, with two justices adding a concurrence, unanimously reversed. It held that for Fair Labor Standards Act purposes, an activity is integral and indispensable and thus compensable only if is an intrinsic element of activities which a worker cannot dispense with if he is to perform his principal activities. Applying here, the screenings were not compensable as Busk could do his duties without doing the screenings and he was not hired to be screened. The concurrence noted that the screenings were not necessary for the safe or effective performance of Busk’s duties and the screenings were more like exiting a factory which has long been understood to not be compensable work.