Improper Contacts With a Juror In Alabama
The appropriate standard for evaluating improper contacts with a juror is stated in Roan v. State, 225 Ala. 428, 143 So. 454 (1932), where the test is articulated in terms of whether the contacts might have had a prejudicial effect on the juror:
"The test of vitiating influence is not that it did influence a member of the jury to act without the evidence, but that it might have unlawfully influenced that juror and others with whom he deliberated, and might have unlawfully influenced its verdict rendered." 225 Ala. at 435, 143 So. at 460.