Can a juror commit a federal crime in order to serve as an juror in a criminal case?

Finally, courts cannot administer justice in circumstances in which a juror can commit a federal crime in order to serve as a juror in a criminal case and do so with no fear of sanction so long as a conviction results. The government's brief exhibits no concern over the possible criminality of the juror's conduct and asks us to affirm without further inquiry. ² Compare United States v. Hand, supra. We do not intend this observation as a rebuke because we realize that the government is confronted by cross-purposes. We also believe that whether the government chooses to prosecute such cases is not for us to decide. We need not reduce its incentives to take such conduct seriously, however, by giving the government cause to believe that overlooking juror misconduct will preserve tainted convictions.