In Remmer v. United States, the Supreme Court ruled that any private communication or contact with a juror during a trial about the matter pending before the jury is considered presumptively prejudicial and if not rebutted by the prosecution, it necessitates a new trial. The case involved Fred W. Remmer who was convicted of tax evasion in federal court but later discovered an external attempt to influence one of his jurors through bribery. He filed for habeas corpus relief on grounds of jury tampering which was denied by lower courts stating no harm had been done as there wasn't enough evidence to prove that this incident influenced verdict's outcome directly or indirectly. However, upon reaching Supreme Court, it reversed these decisions emphasizing on defendant’s right to impartial jury proceedings free from unauthorized intrusions regardless of their apparent harmlessness.

In the dissenting opinion for Remmer v. United States, Justice Jackson argued that the majority's decision to remand the case back to district court was unnecessary and would only serve to prolong litigation without any real benefit. He believed that there was no evidence of prejudice against the defendant due to an alleged jury tampering incident involving a juror receiving an offer of bribe during trial. The FBI had investigated this matter thoroughly and found no cause for concern; thus, he saw no reason why it should be re-examined by a lower court. Furthermore, he pointed out that even if there were some irregularity in how this issue was handled initially, it did not necessarily mean that the defendant’s rights were violated or his trial unfair as long as overall justice was done in his case.