In a medical malpractice case, the Delaware Supreme Court has held that the trial court erred in failing to conduct an investigation when allegations that a juror conducted Internet research were raised. Baird v. Owczarek, No. 504, 2013 (Del., decided May 28, 2014). According to the court, “Internet research by a juror is an improper extrinsic influence that is an egregious circumstance because it has the prospect of being so inherently prejudicial that it raises a presumption of prejudice.” The court also ruled that further investigation by the trial court is mandatory once evidence of Internet research by a juror has been presented. Because the lower court failed to investigate the allegation, the court reversed and remanded for a new trial.