have been directed to return to deliberate further. See Eades, 75 Md.App. at 419, 541 A.2d at 1005-06. In the case at bar the jury had been discharged before the matter was brought to the court’s attention. 20 . See infra. 21 . The Court of Special Appeals did not decide whether the Remmer presumption remains valid in light of Smith and Olano, as it held that the State rebutted any presumption of prejudice, if one existed. Jenkins, 146 Md.App. at 110, 806 A.2d at 697-98. 22 . The State specifically contends, in reference to Smith and Olano, ‘‘applying this most recent precedent from the Supreme Court, no presumption of prejudice should arise automatically from improper jury contact.” 23 . But see the Maryland case of Wernsing v. General Motors Corp., 298 Md. 406, 470 A.2d 802 (1984)(<HOLDING>). 24 . Specifically, the Supreme Court stated
holding that district court had not abused its discretion in denying plaintiffs motion to amend complaint holding that the defendant was not prejudiced by the jurys exposure to the dictionary definition of burglary because the definition referenced theft which was not an element the prosecution was required to prove holding that the trial court abused its discretion in denying a new trial where the jury had taken a dictionary that had not been admitted into evidence into the jury room and had improperly referred to and relied on the dictionarys definition of legal cause that was at variance with the definition of proximate cause holding that the trial court abused its discretion in not allowing defendant to withdraw his waiver of jury trial where a lengthy continuance already had been granted holding trial court abused its discretion by not extending the time for service where the statute of limitations had run and where service had been achieved at the time of the hearing on the motion to dismiss