Harris v. State

Summary

The Supreme Court of Georgia vacated the Court of Appeals’ judgment because both lower courts applied incorrect legal standards to Harris’s claim that jurors conducted extrajudicial research about the severity and potential sentences associated with the charges. The court held that a finding of juror misconduct with the potential to impair due-process rights triggers a presumption of prejudice, that the State must rebut that presumption beyond a reasonable doubt, and that sentencing information cannot be deemed categorically harmless. The case was remanded for the trial court to determine whether the misconduct warranted a new trial.