In State v. Murphy, 91 Ohio St.3d 516, 2001 Ohio 112, 747 N.E.2d 765, the Ohio Supreme Court was faced with the question of whether allowing alternate jurors to be present during the jury deliberations in both the guilty phase and sentencing phase of the trial was error under former Crim.R. 24(F). Id. at 531. The court first noted that it is generally considered erroneous to permit alternates to sit in on jury deliberations. Id. Nevertheless, Ohio's high court further observed that the defendant failed to object to the presence of the alternate jurors during deliberations. Id. at 532. Finding that even a constitutional error can be waived, the court held the alleged error could be reviewed only under a plain error standard pursuant to Crim.R. 52(B). Id. In applying that standard, the court noted that the party complaining "has the burden of showing that the alternates disobeyed the court's instructions by participating in the deliberations either verbally or through their body language, or that their presence chilled the deliberative process." Id. at 533.