What is the current state of the law regarding post-verdict scrutiny of jurors?

¹⁶ Full explication of this topic is unnecessary because, among other reasons, the rationale for discouraging post-verdict contact with jurors has been recited in the case law on many occasions. See, e.g. , Pena-Rodriguez v. Colorado , U.S. , 137 S.Ct. 855, 869, 197 L.Ed.2d 107 (2017) (stressing the importance of limiting counsels post-trial contact with jurors "to provide jurors some protection when they return to their daily affairs after the verdict has been entered"); id. at 865 (emphasizing that restrictions on post-verdict scrutiny of jurors have "substantial merit" because they "give[ ] stability and finality to verdicts" and "promote[ ] full and vigorous discussion by providing jurors with considerable assurance that after being discharged they will not be summoned to recount their deliberations, and they will not otherwise be harassed or annoyed by litigants seeking to challenge the verdict"); United States v. Ianniello , 866 F.2d 540, 543 (2d Cir. 1989) ("[P]ost-verdict inquiries may lead to evil consequences: subjecting juries to harassment, inhibiting juryroom deliberation, burdening courts with meritless applications, increasing temptation for jury tampering and creating uncertainty in jury verdicts.").