The United States Court of Appeals for the Third Circuit held that the use of a questionnaire was inadequate to enable the district court to fulfill its responsibility of determining whether a jury was prejudiced due to premature discussions of the case and that the district court should have conducted a further investigation into the nature and extent of the discussions in order to determine whether the jury was prejudiced.
United States v. Resko, 3 F.3d 684 (3d Cir. 1993).
James P. Thomas,
Constitutional Law - Sixth Amendment - Juror Misconduct - Premature Deliberations,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol32/iss4/15