California, United States of America
The following excerpt is from C.A. v. Arnold, D073402 (Cal. App. 2020):
Even if we were to assume juror misconduct occurred, we would conclude the presumption of prejudice has been rebutted here. The presumption of prejudice arising from juror misconduct "does not mean that every insignificant infraction of the rules by a juror calls for a new trial. Where the misconduct is of such trifling nature that it could not in the nature of things have prevented either party from having a fair trial, the verdict should not be set aside." (Enyart v. City of Los Angeles (1999) 76 Cal.App.4th 499, 507.)
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