The following excerpt is from U.S. v. Al Mudarris, 695 F.2d 1182 (9th Cir. 1983):
A prosecutor may not, by making prejudicial remarks to sway the grand jury, deny an accused his right to have his indictment tested by its independent judgment. United States v. Samango, supra, 607 F.2d at 884. However, it takes substantial proof of grand jury bias to overturn an indictment. United States v. Polizzi, 500 F.2d 856, 888 (9th Cir.1974), cert. denied, 419 U.S. 1120, 95 S.Ct. 803, 42 L.Ed.2d 820 (1975).
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