Information obtained by jurors through internet searches during a trial is treated analogously to extraneous documents finding their way into the jury room, and evidence of such searches is admissible on appeal. However, evidence of jury deliberations about that material remains inadmissible. Where jurors obtain prejudicial information about an accused's prior charges through internet searches, and the trial judge has not given directions addressing that specific prejudice, the Marsland test for procedural irregularity will not be satisfied and a new trial will be ordered. Trial judges should now routinely direct jurors at the commencement of a trial not to undertake any independent research by internet or otherwise.
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