What is the current state of the law on claims of coercive deliberations?

Because of the freedom necessarily accorded jury debate, other jurisdictions appear equally reluctant to entertain claims of coercive deliberations. Many, of course, preclude all inquiry about events inside the jury room. Our research has disclosed only one case in which a claim of intimidation among jurors received favorable consideration. There, in a decision the court itself deemed a departure from general principles, a death judgment was reversed and remanded for consideration of claims that, after 27 hours of deliberations, all 11 majority jurors subjected the lone holdout for life imprisonment to an exhausting and unending torrent of abuse until he acquiesced in a death verdict to escape the pressure. (Wharton v. People (1939) 104 Colo. 260, 90 P.2d 615, 616-620; see also authorities collected in Annot. (1985) 39 A.L.R.4th 800.)