Minnesota has at least 2 appellate decisions on sleeping jurors. And, yes, I have occasionally observed jurors nodding off during trial. (A colleague observed counsel napping during a long trial.)
The MN cases: State v. Yant, 376 NW2d 487, 491 (Minn. App. 1985) and State v. James, 638 NW2d 205, (Minn. App. 2002)
Here is a link to a law review article: http://lawreview.jmls.edu/articles/show/17
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