State v. Cornell
In State v. Cornell, 173 Ariz. 599, 601, 845 P.2d 1094, 1096 (App. 1992), the Court stated, "reference to outside sources, including dictionaries, usually has been found to be harmless error."
Nevertheless, in that case, the Court held a juror's use of a dictionary to review definitions of "aggravate" and "assault" contributed to the verdict and was, therefore, not harmless. Id. at 602, 845 P.2d at 1097.
The juror in Cornell testified that reading the definitions was "like a light bulb going off in my head," and "made my decision for me," and changed his position from "hold-out" to siding with the remaining members of the jury. Id. at 600-01, 845 P.2d at 1095-96.