The case had important implications for secrecy of the jury deliberation process outweighs the ability to dismiss a juror for nullification.

[2] During jury selection for a drug distribution trial, the prosecutor attempted to use a peremptory strike on a black man, empaneled as "Juror No.

The court found that the strike was not racially motivated—the prosecutor's stated reason was that the juror failed to make eye contact—but improperly denied the challenge anyways.

5 was distracting them in court by squeaking his shoe against the floor, rustling cough drop wrappers in his pocket, and showing agreement with points made by defense counsel".

5 for his cantankerous conduct but also his perceived refusal to convict because of "preconceived ... reasons that are totally improper and impermissible."