Manuel Tarango, Jr. v. E. McDaniel

I agree with the majority that if a member of the Las Vegas Metropolitan Police Department purposefully tail-gated a holdout juror on the freeway for over seven miles, because the juror was a holdout, such conduct might constitute external jury contact requiring further inquiry from the court. However, the Nevada Supreme Court determined that the juror’s assumption that the police officer targeted him as the holdout juror was speculative and unsubstantiated.1 As recognized by the majority, the Nevada Supreme Court expressly found that “there was no evidence of an improper external influence…