The court interviewed the juror (#8) and she denied seeing the blog mentioned above or discussing it with other jurors.. The court declined to interview any other jurors. This was followed by still other posts from alleged jurors about #8's comments. The trial court declined motions for reconsideration and new trial. The appeal followed.
The Court of Appeals has remanded the case for an evidentiary hearing. The moral here: TRIAL JUDGES MUST THOROUGHLY INQUIRE INTO ALLEGED MISCONDUCT BY JURORS DURING DELIBERATIONS.
U.S. v. Zimny: http://cases.justia.com/federal/appellate-courts/ca1/15-2144/15-2144-2017-01-24.pdf?ts=1485284403