Ballinger v. Watkins

Summary

The Supreme Court of Georgia affirmed habeas relief based on juror misconduct. A juror independently conducted a drive test to evaluate a critical timing issue in the State’s case, contrary to the trial court’s instructions, and the court held that Watkins established actual prejudice because the test supplied at least one juror with extraneous information resolving a heavily disputed issue. The court did not reach the separate Brady and Napue grounds because the juror-misconduct claim independently warranted relief.