Competency of Juror as Witness (N.C.R. Evid. 606)
"Rule 606(b) reflects the common law rule that affidavits of jurors are inadmissible for the purposes of impeaching the verdict except as they pertain to extraneous influences that may have affected the jury's decision. Cummings v. Ortega, 365 N.C. 262, 267, 716 S.E.2d 235, 238-39 (2011)(quotation marks omitted).
"[D]etermining whether jurors may present post-verdict testimony about alleged juror misconduct pursuant to Rule 606(b) depends on 'the nature of the allegation,' not when the misconduct allegedly occurred. Cummings v. Ortega, 365 N.C. 262, 270, 716 S.E.2d 235, 241 (2011).
"Rule 606(b) of the North Carolina Rules of Evidence bars jurors from testifying during consideration of post-verdict motions seeking relief from an order or judgment about alleged predeliberation misconduct by their colleagues. Cummings v. Ortega, 365 N.C. 262, 270, 716 S.E.2d 235, 240-41 (2011).