Does a judge have to conduct a security inquiry into a juror's communications with the jury?

MultiRegion, United States of America

The following excerpt is from U.S. v. Mehta, 919 F.3d 175 (2nd Cir. 2019):

We do not suggest that such an inquiry is necessary whenever a juror raises a security concern. "The mere occurrence of an ex parte conversation between a trial judge and a juror does not constitute a deprivation of any constitutional right." United States v. Gagnon , 470 U.S. 522, 526, 105 S.Ct. 1482, 84 L.Ed.2d 486 (1985) (per curiam). Taken collectively, however, the aforementioned decisions run contrary to our instructions on the handling of jury communications and implicate the precise concerns that animated our decision in Collins .

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