Hall v. Zenk

Dist. Ct. erred in denying defendant's habeas petition challenging his murder conviction on ground that his jury was not impartial when fellow inmate of defendant informed relative, who was on jury in defendant's trial, that inmate and others in jail believed that defendant was guilty of charged offense. Record supported defendant's claim that inmate's information reached jurors, and while defendant was required in instant habeas proceeding to show that he was prejudiced by any constitutional error, underlying trial court erred in rejecting defendant's argument that govt. had burden of proof to show that extraneous information from inmate was not prejudicial to outcome of defendant's trial. Thus, remand was required to allow govt. ability to convince Dist. Ct. through countervailing facts that such information might not have impacted jury's verdict.