Whether a lower court can rule that a verdict was not affected by juror misconduct when the exact websites and content viewed by the juror are unknown and unclear

QUESTION PRESENTED In this case, juror misconduct was proven by the lower court after a juror researched an | element of the crime on the internet (Wikipedia) during deliberations. The exact websites and content viewed some 14 months earlier are unknown and unclear. Therefore, under } Remmer, how can a,lower court rule that the verdict was not affected with this uncertainty in the air? The 4" Circuit in Lawson and the 9" Circuit in Arndt concluded differently with this materially indistinguishable fact of the “unknowns.” Therefore, this novel i circumstance warrants the exercise of this Court’s discretionary power. | | | | | | | 1