Does the trial court abuse it discretion in denying a motion for new trial without an evidentiary hearing when a juror was texting on his cell phone during sidebars?

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Does the trial court abuse it discretion in denying a motion for new trial without an evidentiary hearing when a juror was texting on his cell phone during sidebars? You may be surprised.

Watch SM JUROR’s video analysis of the juror misconduct issues in State v. Pyle, 2018-Ohio-3160. Issues involve possible juror misconduct, oral motions for new trial, affidavits, duty to investigate, refusal to hold an evidentiary hearing and cell phone use.

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Don’t let juror misconduct taint your next verdict…