The following excerpt is from Jackson v. Hedgpeth, No. 2:12-cv-0691 TLN CKD P (E.D. Cal. 2014):
Moreover, no other factors in the record suggest that the jury was impermissibly coerced into reaching a verdict. The trial judge gave the "firecracker" instruction only once, and "did not know the identity of the holdouts . . . ; there is thus no way that any of the holdout jurors could have thought the judge was directing the instruction specifically at him." United States v. Ajiboye, 961 F.2d 892, 894 (9th Cir. 1992).
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