How have courts dealt with employment applications during a criminal trial?

The first, Smith v. Phillips (1982) 455 U.S. 209, 102 S.Ct. 940, 71 L.Ed.2d 78, involved facts that in some respects are more troubling than those here. The defendant was convicted by jury of crimes in state court. During the trial, one of the actual jurors applied "for employment as a major felony investigator in the District Attorney's Office." (Id. at p. 212, 102 S.Ct. at p. 943.) When the defendant learned of this after trial, he unsuccessfully moved to set aside the verdict. The trial court found that the employment application " 'was indeed an indiscretion,' " but it did not indicate prejudice against the defendant or an inability to decide guilt or innocence " 'solely on the evidence.' " (Id. at pp. 213-214, 102 S.Ct. at pp. 944.)