California, United States of America
The following excerpt is from People v. Dell, 232 Cal.App.3d 248, 283 Cal.Rptr. 361 (Cal. App. 1991):
On the other hand, the determination of good cause for dismissal after a juror's request to be dismissed does not always require a hearing. A juror's disqualification is discretionary with the court and if there is any substantial evidence supporting the decision it will be upheld on appeal. (People v. Farris (1977) 66 Cal.App.3d 376, 386, 136 Cal.Rptr. 45.)
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