Hall v. Wilson, No. 11-3911 (7th Cir. 2012)
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In 2001, Hall was convicted in state court of murdering his stepson. Shortly after his verdict came down, Hall discovered that one of his jurors had a son that was a fellow inmate of his. Before his trial, the juror’s son informed the juror that Hall was likely innocent, but during the trial, the juror found out that his son and several co-inmates changed their mind about Hall, and thought him guilty. The juror relayed this information to several jurors. The state court rejected Hall’s motion to correct error, and Hall was denied relief on direct appeal. After unsuccessfully seeking collateral relief in Indiana, Hall filed a federal habeas petition, arguing that the state should have carried the burden of proving that the extraneous information that reached his jury was not prejudicial. The district court granted the petition. The Seventh Circuit vacated and remanded, holding that the state court violated a clearly established constitutional right, but did not adequately address the issue of prejudice. The district court erred in presuming prejudice.
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