In U.S. v. Lawson, the 4th Circuit Court of Appeals recently overturned the cockfighting convictions of several defendants. The reversal was due to juror misconduct in the form of online research. Specifically, a juror (177), after a day of deliberations, went home and researched the term "sponsor" on Wikipedia. "Sponsor" was an element of the animal fighting statute that the defendants were accused of violating. Juror 177 also brought in the results of his research to the jury room and shared the material with other jurors.
Upon learning of Juror 177's actions, the trial court held a hearing to investigate whether the guilty verdicts had been tainted. The trial court ultimately determined that there was no reasonable possibility that the external influence caused actual prejudice. Thus, the trial court denied the defense's motion for a new trial based on a violation of the 6th Amendment right to a fair trial. In overturning the trial court's decision, the Court of Appeals determined that because the government has a "heavy obligation" to rebut the presumption of prejudice by showing that "there is no reasonable probability that the verdict was affected by the" external influence, [], the government's showing in this case, as a matter of law, does not satisfy that obligation. The Court of Appeals then went on to vacate the appellants' convictions under the animal fighting statute, and...award them a new trial with respect to those charges.
