California, United States of America
The following excerpt is from People v. Trujillo, B246471 (Cal. App. 2014):
While Evidence Code section 1150 allows evidence of statements made within or without the jury room, it is only in "rare circumstances" that a statement by a juror during deliberations "may itself be an act of misconduct . . . ." (People v. Hedgecock, supra, 51
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