This law review article raises few issues not previously discussed in this blog, but the writer does focus on the unique problem of discovering a juror's texting as opposed to a juror commenting on Facebook or Twitter. He concludes that as to texting the issue is not what the texter sends but rather what they receive via text message.
http://lawreview.syr.edu/wp-content/uploads/2017/03/Vol-67.1-Powers.pdf
http://lawreview.syr.edu/wp-content/uploads/2017/03/Vol-67.1-Powers.pdf
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