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Juror found in contempt for sharing findings of internet research

In Attorney-General -v- Theodora Dallas (2012) the Divisional Court heard that a jury member (Dallas) had conducted independent internet research in relation to a criminal trial she was sitting on. she had then discussed her findings with her fellow jury members.

At the start of the case the jury had been shown a video about their responsibilities and told not to conduct independent research on the case or the [criminal] defendant. Dallas had undertaken internet research and come across an online article that suggested the defendant had a previous conviction for an offence in which another man had committed rape.  she brought her findings to the attention of her fellow jury members.  The court was notified and the jury discharged.

Dallas stated she had not understood the warnings properly as English was not her first language. she submitted she stumbled across the article and did not intend to disrupt the trial process, influence anybody or prejudice the jury's decision.  These arguments were rejected by the Court. The result of Dallas's actions was that the jury had to be discharged and a retrial ordered. The complainant had to repeat his evidence and relive his ordeal.  Jurors' time was wasted and the public purse was put to additional unnecessary expense. The Court found that the damage to the administration of justice was obvious. The contempt was proved.  In passing a sentence of six months' imprisonment the Court stated that misuse of the internet by a juror was a most serious irregularity and a custodial sentence was almost always inevitable.

The Court further commented that in the context of alleged contempt by or affecting a juror or jury in the Crown Court, unless it was appropriate for the Crown Court to deal immediately with the contempt of its own motion (which would be rare given the warnings given), such cases of contempt should continue to be left to proceedings by the Attorney General and that trials for contempt of court on indictment were obsolete.


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