United States v. Spruill, No. 13-4069 (2d Cir. 2015)
Annotate this CaseDefendant appealed his conviction for drug- and firearm-related crimes, arguing that the district court erred in dismissing a "holdout" juror for cause during the course of jury deliberations, in violation of United States v. Thomas. The court rejected defendant's claim for two reasons: first, the challenged removal is not subject to Thomas’s “any possibility” rule, because the concern underlying Thomas, juror nullification, was not here at issue; and second, defendant waived any challenge to dismissal of the juror in question by specifically telling the district court that he did not object either to its colloquy with the juror or to the juror’s removal, and by in fact recommending the very disposition he now challenges. The court rejected defendant's remaining arguments and affirmed the judgment.
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