How have courts dealt with the issue of inattentiveness of a juror?

More instructive given the circumstances of this case is People v. Bradford (1997) 15 Cal.4th 1229. There, the trial court observed that a juror was asleep during defense counsel's cross-examination of a detective. (Id. at pp. 1347-1348.) Our high court noted that the record showed "no more than that the juror had fallen asleep on the day in question and appears to have been asleep one day earlier; it d[id] not appear that the juror continued to fall asleep or had been asleep for a longer period of time." (Id. at pp. 1348-1349.) The defense counsel did not argue juror misconduct or request a hearing, and the trial court made no further inquiry regarding the juror's attentiveness. The reviewing court concluded the lower court did not abuse its discretion in failing to inquire about possible juror misconduct in light of the "absence of any reference in the record to the juror's inattentiveness over a more substantial period." (Id. at p. 1349.)