Chambers v. State, 321 Ga. App. 512

Chambers, age 17 at the time, was convicted after a jury trial of aggravated assault, felony murder, and voluntary manslaughter as a lesser-included offense; the three counts were merged and Chambers was sentenced to 20 years.
The prosecution's witnesses testified about the shooting incident in a parking lot where L. J. Gilliam Jr. was killed; the gun recovered from Chambers matched the ballistics.
Chambers asserted affirmative defenses of justification and defense of habitation as it pertains to a motor vehicle.
During deliberations, Juror 38 conducted internet research and shared legal definitions with other jurors, including material related to defense of habitation.
The trial court denied a motion for new trial; on appeal, the State was unable to prove beyond a reasonable doubt that juror misconduct did not prejudice Chambers.
The appellate court held the juror misconduct potentially prejudicial and reversed the judgment, remanding for retrial, with other arguments deemed moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Juror misconduct prejudiced the defendant	Chambers argues the state failed to prove no prejudice	State contends no prejudice shown	Yes, prejudicial error; reversal warranted

Sims v. State, 266 Ga. 417 (1996) (juror misconduct analysis; evidentiary impact on verdict)
Inman v. State, 281 Ga. 67 (2006) (Sixth Amendment right to jury trial and impartiality)
Steele v. State, 216 Ga. App. 276 (1995) (juror misconduct; reliance on extraneous information)
Shaw v. State, 83 Ga. 92 (1889) (early juror misconduct precedent; external influence invalidates verdict)
Turner v. Louisiana, 379 U.S. 466 (1965) (due process and right to an impartial jury)