Jones v. First American Title Insurance

How later courts describe this case

• no error where court brought to attention of counsel that a juror appeared to be sleeping, but neither side requested juror replacement
• for Barker purposes the court separately considered the lapse of time before the first trial and the lapse of time from the first trial to the retrial
• “The critical inquiry under the independent source doctrine is whether the challenged evidence was obtained from lawful sources and by lawful means independent of the police misconduct.”
• effect on jury panel of juror statement "They ought to hang him now so we can all go home” may not be the basis of a motion for a new trial because you may not inquire into thoughts and reactions of jurors