Published on: Saturday, April 24, 2021

After an Ohio man is convicted of rape by cunnilingus, a juror informs the court that another juror introduced into deliberations extraneous information that the defendant was from Sierra Leone and had a criminal record. Sixth Circuit: Because all the physical evidence was inconclusive, this case came down to witness credibility, and the improper outside evidence by juror can rarely be harmless. The man may be entitled to a new trial, even though he has been released from his prison sentence.

The case is Nian v. Warden, North Central Correctional Institution, No. 18-3938 (6th Cir. Apr. 19, 2021).