Shook v. United States

How later courts describe this case

• holding that when evidence of potential misconduct is brought to the trial judge’s attention, he has a “duty to investigate whether there may have been a violation of the sixth amendment.”
• finding no hearing necessary where juror spoke to wife during deliberations, but noting that a trial court’s refusal to permit an evidentiary hearing may constitute an abuse of discretion when the alleged jury misconduct involves extrinsic influences