State v. Abdi, 45 A.3d 29

Defendant, a Somali Bantu immigrant, was tried for aggravated sexual assault on a child after a family gathering where the victim alleged contact by defendant.
Evidence included testimony from the victim, her brother, and Somali Bantu elders about culture and religion influencing conduct and credibility.
Elders’ questioning of defendant followed Somali customs requiring three denials and potential swearing on the Koran.
Jury deliberations reportedly included extraneous internet information concerning Somali culture and religion.
The court held a three-day post-trial hearing; while finding an irregularity with capacity to affect the verdict, it ruled the evidence was not prejudicial and denied a new trial.
The Vermont Supreme Court reversed, holding the extraneous information prejudiced the defendant and remanded for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extraneous information to the jury about Somali culture could prejudice the verdict	Abdi	Abdi’s trial was fair; no prejudice shown	Prejudicial; reversal and new trial required

Parker v. Gladden, 385 U.S. 363 (1966) (juror deliberations and confrontation rights protect fair trial)
Turner v. Louisiana, 379 U.S. 466 (1965) (verdict must be based on evidence presented at trial)
McKeen, 165 Vt. 469 (1996) (heavy burden to show extraneous influence prejudiced verdict)
Lee, 185 Vt. 110 (2008) (Rule 606(b) applying objective totality of circumstances)
Squiers, 179 Vt. 388 (2006) (harmlessness standard for extraneous information)
Hudson, 163 Vt. 316 (1995) (courts may inquire into extraneous prejudicial information within limits)