The Pennsylvania Supreme Court adopted the objective test for prejudice, as well as the associated guidelines that are set forth in Carter by Carter v. United States Steel Corp., in instances of post-verdict allegations of extraneous information and/or outside influence affecting jury deliberations.
Pratt v. St. Christopher's Hospital, 866 A.2d 313 (Pa. 2005).
Robert A. Gallagher,
Pennsylvania's Exception to the No-Impeachment Rule regarding Jury Deliberations Affected by Extraneous Information: Pratt v. St. Christopher's Hospital,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol44/iss3/10