How have courts dealt with prejudicial juror misconduct in civil cases?

The court also found prejudicial juror misconduct in People v. Cissna (2010) 182 Cal.App.4th 1105. There, the defense learned after the defendant was convicted that a juror debated the "merits of the case every single day" with a non-juror friend. The court held the juror's misconduct was "tantamount to inherent bias" because the "content and frequency" of his discussions with his friend "strongly suggest[ed]" that the juror was influenced by his friend's input. (Id. at p. 1122.)