In Gonzales v. State, 3 S.W.3d 915 (Tex. Crim. App. 1999), the juror answered "no" in response to whether he had ever been an accused, a complainant, or a witness in a criminal case, on the written questionnaire. Gonzales, 3 S.W.3d at 916. Later, the defendant learned that the juror was a complainant in a pending criminal case and a motion for new trial followed, contending that the juror withheld information that deprived him of his ability to intelligently exercise his peremptory challenges. Id. The Court of Criminal Appeals noted that juror questionnaires are "vulnerable to misinterpretation" and thus the burden falls on counsel to exercise due diligence to elicit pertinent information during voir dire. Id. at 916-17. "Diligent counsel," according to the Court, "will not rely on written questionnaires to supply any information that counsel deems material. Counsel who does otherwise is simply not diligent." Id. at 917. Because counsel did not follow up on the written questionnaire by "verifying whether prospective jurors who returned juror questionnaires had been involved in criminal cases as that question was meant to be understood," the Court determined that the juror did not withhold information, and therefore, there was no juror misconduct. Id. at 917-18. The Court of Criminal Appeals explained that counsel's burden to use diligence requires oral questioning during voir dire to follow up on any written response from a prospective juror that counsel deems material. The Court observed: "While a questionnaire may serve as an efficient vehicle for collecting demographic data, it is not the most reliable way to collect other types of information. Counsel should never assume that the respondents will understand each question as it was intended by counsel to be understood. . . . Written questions are by nature vulnerable to misinterpretation--even questions that appear to be subject to only one interpretation." 3 S.W.3d at 917.