The following excerpt is from U.S. v. Angulo, 4 F.3d 843 (9th Cir. 1993):
Here, the potential for bias is so strong that the judge was obliged at a minimum to hold a hearing. 7 In cases where a bribe or a threat to a juror was communicated to the other jurors, the trial judge must fully examine the effect of the threat on the remaining jurors. See, e.g., United States v. Sublet, 644 F.2d 737, 740-41 (8th Cir.1981)
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