Does a juror need to actually discuss the case or receive information about the case from a nonjuror?

Defendant argues that it is not necessary for a juror to actually discuss the case or receive information about the case from a nonjuror for his or her conduct to amount to misconduct. The cases defendant cites in support of this contention, however, are not applicable to his case. In People v. Ryner (1985) 164 Cal.App.3d 1075, 1080, the court found juror misconduct occurred when "a number of the jurors" engaged in a conversation with a prosecution witness even though the jurors did not discuss matters

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related to the case. The court found misconduct because "the jurors' friendly conversation with [the witness] might well have caused them to accord his testimony greater credibility." (Id. at p. 1082.) The same reasoning was true in People v. Jackson (2016) 1 Cal.5th 269, where "several of the jurors" asked a prosecution witness questions during a break. (Id. at pp. 294, 331, 333.)