Ohio Holding Co. v. Masheter

How later courts describe this case

• determining that the legislative history of Exemption 7 supports the interpretation that the exemption is not limited to criminal investigations
• affirming Collyer rule of NLRB deferral to grievance and arbitration procedures
• not every instance of misconduct warrants a new trial; test is whether misconduct has prejudiced the defendant to the extent he did not receive a fair trial
• no mistrial warranted when one juror states by affidavit that nine of the jurors expressed opinions as to guilt before the close of the case, given jury’s impartiality evidenced by their request for re-reading of court’s instructions on sole issue in the case
• jurors discussing case prior to deliberation