The Statev.Ryan Melly
Ryan Melly was convicted of multiple sexual offenses involving minors. After trial, a juror disclosed that another juror had possessed a screenshot containing statistics about child-abuse allegations during deliberations. The trial court treated the disclosure as juror misconduct and granted Melly a new trial. The State appealed. The Court of Appeals held that the extraneous information did not warrant a new trial because the record did not show a reasonable probability that it contributed to the verdict. The screenshot was not shown to have supplied legal guidance or materially affected deliberations, and the evidence did not establish that the jury’s decision was based on it. The court distinguished cases in which jurors obtained outside information, shared it with other jurors, and used it to evaluate disputed evidence or legal rules. Because Melly was not harmed by the misconduct shown in the record, the Court of Appeals reversed the order granting a new trial.
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