United States v. Rakes

During Rakes's (defendant's) banking-crimes trial, a man named Martin offered a bribe to juror Madison, who promptly reported it to the judge; the judge found the incident hadn't unduly influenced Madison and let him remain on the jury. On the third and final night of deliberations, Madison discussed the bribe offer with several fellow jurors, and the jury convicted most defendants the next morning. On remand for a new judge to hear a motion for a new trial, jurors testified they hadn't been improperly influenced by either the bribe or Madison's disclosure of it.