A less severe consequence of misconduct is a juror’s dismissal from service. Jurors are often ejected from trials when they violate court orders to refrain from Internet use. One such juror was Jonathan Hudson. Hudson was dismissed from service after he attempted to “friend” the defendant in his case on Facebook. 32 Another juror, a high-school librarian, was dismissed from the jury panel for conducting online research on the victim’s injuries. 33 A juror in Lancastershire, England was dismissed after it was discovered that she was posting information about the child abduction/sexual assault trial she was hearing and taking a poll on whether to vote in favor of the defendant’s guilt. 34 IV. METHODS OF PREVENTING JUROR MISCONDUCT The availability of Smart phones, tablets, and laptops enable the use of the Internet virtually anywhere. People can surf the Internet in banks, shopping malls and even on airplanes. The courthouse, therefore, is certainly not off limits. While judges frequently warn them against Internet use, unfortunately, admonitions are not enough. For this reason, many courts have developed strategies for curtailing Internet use and the imposition of punishment for jurors who violate directives. A. Bans, Confiscations and Restriction of the Use of Electronic Devices The judiciary has taken steps to eliminate the occurrence of juror transgression by limiting the availability and use of electronic devices. Some courts in Indiana and Oregon completely ban electronic devices 35 as do many in Delaware, Florida, Illinois, Michigan, New Mexico, and Ohio.