California, United States of America
The following excerpt is from Rempell v. Hofmann, A146257 (Cal. App. 2018):
People v. Russell (2010) 50 Cal.4th 1228, which involved the court's duty to investigate juror misconduct during deliberations after it was brought to the court's attention and discussed with counsel; it is simply not analogous to the situation presented here. (Id. at pp. 1248-1249.)
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