Ballinger v. Watkins

Summary

The court affirmed habeas relief because a juror independently conducted a drive test that introduced extrajudicial information bearing directly on whether Watkins could have been at the crime scene. Even assuming Watkins had to prove actual prejudice rather than receive a presumption of prejudice, the court held that the test actually and substantially disadvantaged him because it resolved a critical, disputed timing issue for at least one juror. The court did not address the separate Brady and false-testimony claims because the juror-misconduct ground independently warranted relief.