Liberalizing the Mansfield Rule in Missouri: Making Sense of the Extraneous Evidence Exception after Travis v. Stone

In Missouri, to obtain a new trial based on juror misconduct, a two step process must be used. First, admissible evidence of misconduct must be presented, and second, the evidence of misconduct must be sufficient to convince the trial court that the misconduct prejudiced a party. This Note examines the current status of Missouri law governing the first prong of this analysis: the admissibility of juror testimony offered to establish juror misconduct involving the gathering of extra-judicial evidence.