State v. Williams, 2025 Ohio 3105

Ahmad Williams was convicted by a jury of murder and felonious assault in connection with the death of his infant son, alleged to have been caused by abusive head trauma.
After the verdict, Juror 10 expressed post-trial remorse via a letter and affidavit, claiming their guilty vote was influenced by Juror 3, a former ER nurse, during deliberations.
Williams moved for a new trial, arguing juror misconduct based on Juror 3's input constituting improper "extraneous prejudicial information."
The trial court held an evidentiary hearing, subpoenaed all jurors, and explored the extent of Juror 3’s statements and their impact.
Despite testimony from almost all jurors that deliberations were fair and independent with no outside research or coercion, the trial court granted Williams a new trial, reasoning Juror 3’s input was improper and prejudicial.
The State appealed, arguing the trial court misapplied the law regarding what constitutes "extraneous" juror misconduct, and the appellate court reviewed the decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a juror’s use of their professional experience during deliberations “extraneous prejudicial information”?	Not extraneous; experience is internal to jurors and permitted unless outside research is involved.	Such input constitutes improper influence, in effect expert testimony not presented at trial.	Not extraneous; juror background/experience is permissible if no outside info used.
Should the trial court have granted a new trial for juror misconduct?	No, as there was no actual misconduct or prejudice; all but one juror denied undue influence.	Yes, as Juror 3's statements likely had prejudicial impact.	No new trial; record overwhelmingly showed no prejudice or actual misconduct.
Did the trial court abuse its discretion in finding juror misconduct and prejudice?	Yes; findings were speculative and contrary to juror testimony and established precedent.	No; Juror 3’s conduct was outside proper juror role.	Yes; abuse of discretion in ignoring actual juror testimony and applying wrong legal standard.
Was Evid.R. 606(B) (regulating juror testimony about deliberations) correctly applied?	Yes; only "external" information is prohibited, not internal experiences.	No; should also bar internal professional opinions that function as new evidence.	Yes; only external sources are "extraneous"—professional background is not.

State v. Ford, 2019-Ohio-4539 (key for distinction between internal juror experience and extraneous information influencing deliberations)
Tanner v. United States, 483 U.S. 107 (privacy and finality of jury deliberations; only external influences can impeach a verdict)
Warger v. Shauers, 574 U.S. 40 (distinguishing external and internal information for juror influence)
Smith v. Phillips, 455 U.S. 209 (actual, not speculative, prejudice needed for new trial based on juror misconduct)
State v. Hessler, 90 Ohio St.3d 108 (verdict finality; exceptions to impeachment of verdict are limited)