The following excerpt is from Brydges v. Copeland, 43 F.3d 1478 (9th Cir. 1994):
Juror misconduct requires a new trial only if there is a reasonable probability that extrinsic evidence affected the verdict. Bayramoglu v. Estelle, 806 F.2d 880, 887 (9th Cir.1986). In order to make that determination, federal habeas courts should consider whether the extrinsic material was actually received; at what point during deliberations it was introduced; the extent to which the jury discussed and considered it; and any other matters that may bear on the possibility of whether the introduction of extrinsic material affected the verdict. Id.
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