State v. Williams

Court of Appeals of Ohio, Sixth Appellate District, Lucas County · 2025 · Criminal Law

2025 Ohio 3105 (2025)

Updated August 1, 2026

Criminal Lawnegligent homicidejuror misconductnew trialjury deliberationsextraneous prejudicial informationEvid.R. 606(B)internal vs external influence

Facts

During voir dire, Juror 3 disclosed being a registered nurse and former emergency room nurse, and Williams did not object to seating that juror. After the jury returned guilty verdicts, Juror 10 sent the trial judge a letter and affidavit claiming Juror 3 used nursing experience during deliberations to persuade jurors that the infant's symptoms and injuries reflected abusive head trauma rather than accident. The trial court held an evidentiary hearing at which all 12 jurors testified; collectively, they stated deliberations were cordial, Juror 3 did not conduct outside research or tell jurors to ignore instructions, and most jurors said their verdicts were based on the trial evidence and not influenced by Juror 3. The trial court nevertheless granted a new trial, concluding Juror 3 had introduced improper extrinsic information.

Issue

Whether a juror's comments during deliberations, based on the juror's own preexisting medical education and work experience and framed in discussion of the trial evidence, constitute 'extraneous prejudicial information' amounting to jury misconduct under Evid.R. 606(B)(2)(a), Crim.R. 33(A)(2), and R.C. 2945.79(B). Also, if so, whether the defendant established actual prejudice warranting a new trial.

Rule

For purposes of Evid.R. 606(B)(2)(a), information is 'extraneous prejudicial information' only if it comes from a source external to the jury, such as outside publicity, newspapers, dictionaries, or personal investigation of the facts. A juror's reliance on personal knowledge, education, professional qualifications, and life experience brought into the jury room before service is an internal matter, not extraneous information. A new trial for jury misconduct under Crim.R. 33(A)(2) and R.C. 2945.79(B) requires both actual misconduct and actual prejudice affecting the outcome; speculation about how a hypothetical average juror might be influenced is insufficient.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a homicide trial in Columbus, one juror is a licensed paramedic who disclosed that background during voir dire and was seated without objection. During deliberations, other jurors ask him whether the victim’s bluish skin and slowed breathing, as described by trial witnesses, are consistent with oxygen deprivation, and he answers based only on his preexisting training and the testimony admitted at trial.

If the defendant moves for a new trial on the ground that the paramedic-juror injected improper information into deliberations, how should the court rule?

Explanation. The majority rule is that information is extraneous only if it comes from a source external to the jury. A juror’s statements grounded in personal education, professional qualifications, and life experience brought into the jury room before service are internal matters, especially when tied to the trial evidence and not to outside research or investigation. So the defendant has not shown misconduct under Evid.R. 606(B)(2)(a).