In conspiracy and arson trial, reversing and remanding when trial court failed "to make adequate inquiries regarding news stories" that appeared during deliberations and their impact on juror’s deliberations; the judge erroneously failed to explore "whether any juror heard any of the information" and its impact on the jury, in United States v. Waters, __ F.3d __ (9th Cir. Sept. 15, 2010) (No. 08-30222)
The Ninth Circuit recently considered the trial court’s responsibilities to make specific inquiry of jurors when "adverse publicity occurs during deliberations" of the jury. The case can help clear up confusion about the role of the trial court, particularly in light of FRE 606(b) limiting inquiry into a verdict.
I would imagine the media access and media impact issues are going to have a continuing interest in court-martial cases under the UCMJ – Hasan, the Stryker Brigade cases, Wikileaks and Manning, to name a few.