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This Note explores the majority opinion and the dissents in Pena- Rodriguez regarding whether the Supreme Court has adequately provided guidance for lower courts to follow the ruling, which now allows exceptions for evidence of racial bias to Rule 606(b). Part I discusses the history of the no-impeachment rule, its foundation in the Sixth Amendment, and its constitutional requirements. Further, Part I discusses the different approaches that courts have taken in adopting Rule 606(b) and what problems courts have identified in its application. Part II analyzes whether the Supreme Court, as a practical matter, has provided a workable procedural scheme for lower courts to follow in meeting their new legal obligation to consider a juror’s racial bias after the verdict, or whether the Court has left open important considerations, creating precedent that will further erode the protections of the no-impeachment rule. Finally, Part III proposes actions that the Supreme Court could take to clarify questions raised by the Pena-Rodriguez ruling.