Fickes v. Petrolane-Alaska Gas Service, Inc
In Fickes v. Petrolane-Alaska Gas Service, Inc. 628 P.2d 908 (Alaska 1981), the court found juror misconduct when the juror did not tell the court during voir dire that he knew one of the parties' witnesses. This juror later relied on his knowledge of the witness to insert outside evidence into the jury deliberations. The Alaska Supreme Court held that:
This failure by a juror to acknowledge an acquaintance with a witness, and then to argue the probability of a fact to co- jurors based on that acquaintance, that is, based on evidence outside the record, constitutes an obstruction of justice.