A holdout juror in a murder case talked to an attorney about being badgered by the other jury members. The attorney appears in court to inform the judge about the conflict. The judge removes the juror. An alternate juror is seated, and the jury returns a guilty verdict within 90 minutes.
A Sixth Amendment violation? Sixth Circuit: No. She was removed for violating the judge's order not to discuss the case with anyone, not because she was a holdout.
Wofford v. Woods, no. 18-2367 (6th Cir. Aug. 13, 2020).