Larry Heuer & Steven Penrod.  "Juror Notetaking and Question Asking During Trials."  18 Law & Human Behavior 121 (1994).

Warren D. Wolfson.  "An Experiment in Juror Interrogation of Witnesses." 1 CBA Report 12 (Feb. 1987).

American Judicature Society.  Toward More Active Juries: Taking Notes and Asking Questions (1991).

Michigan v. Heard, 200 N.W.2d 73 (1972) (holding that the questioning of witnesses by jurors and the method of submitting juror questions to the witnesses lie within the sound discretion of the trial judge).

Ratton v. Busby, 326 S.W.2.d 889 (Ark. 1959) (holding that multiple questions by jurors to witnesses to obtain explanation about technical terminology used in expert testimony did not deprive the defendant of a fair trial).

Carter v. State, 234 N.E.2d 650 (Ind. 1968) (holding that a preliminary jury instruction that jurors were forbidden to ask questions of witnesses was reversible error).