violate petitioner's Sixth Amendment rights as applied to the States through the Fourteenth." In Ballew v. Georgia, , the Supreme Court ruled that the number of jurors could not be reduced below six. In Brownlee v The Queen (2001) 207 CLR 278, the High Court of Australia unanimously held that a jury of 12 members was not an essential feature of "trial by jury" in section 80 of the Australian Constitution. In Scotland, a jury in a criminal trial consists of 15 jurors, which is thought to be the largest in the world. In 2009 a review by the Scottish Government regarding the possibility of reduction led to the decision to retain 15 jurors, with the Cabinet Secretary for Justice stating that after extensive consultation, he had decided that Scotland had got it "uniquely right". Trials in the Republic of Ireland which are scheduled to last over 2 months can, but do not have to, have 15 jurors. A study by the University of Glasgow suggested that a civil jury of 12 people was ineffective because a few jurors ended up dominating the discussion, and that seven was a better number because more people feel comfortable speaking, and they have an easier time reaching a unanimous decision. Integrity For juries to fulfill their role of analyzing the facts of the case, there are strict rules about their use of information during the trial. Juries are often instructed to avoid learning about the case from any source other than the trial (for example from media or the Internet) and not to conduct their own investigations (such as independently visiting a crime scene). Parties to the case, lawyers, and witnesses are not allowed to speak with a member of the jury. Doing these things may constitute reversible error. Rarely, such as in very high-profile cases, the court may order a jury sequestered for the deliberation phase or for the entire trial. Jurors are generally required to keep their deliberations in strict confidence during the trial and deliberations, and in some jurisdictions even after a verdict is rendered. In Canadian and English law, the jury's deliberations must never be disclosed outside the jury, even years after the case; to repeat parts of the trial or verdict is considered to be contempt of court, a criminal offense. In the United States, confidentiality is usually only required until a verdict has been reached, and jurors