California, United States of America
The following excerpt is from People v. Von Villas, 10 Cal.App.4th 201, 13 Cal.Rptr.2d 62 (Cal. App. 1992):
The principal concern of courts when reviewing allegations of jury misconduct is that "new evidence" prejudicial to a party was presented to the jury outside the trial milieu. (People v. Cooper (1979) 95 Cal.App.3d 844, 853, 157 Cal.Rptr. 348.) Here there was no such "new evidence" presented.
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