Supreme Court of Georgia
Beck v. the State.
March 4, 2019825 S.E.2d 184
Summary
The court vacated the denial of Beck's motion for a new trial and remanded for the trial court to reconsider his claim that jurors received extraneous sentencing information. The trial court had relied on juror testimony about the effect of the information on deliberations, but the governing evidence rule permits juror testimony about whether extraneous information reached the jury while generally barring testimony about internal deliberations and subjective effects. The court did not reach Beck's other claims because they were unlikely to recur if a retrial occurred.