What is just cause for excusing a juror from jury?

Although "just cause" generally focuses on sickness, family emergency, or juror misconduct, it "embraces all kinds of problems--temporary as well as those of long duration--that may befall a juror during jury deliberations." Murray v. Laborers Union Local No. 324, 55 F.3d 1445, 1452 (9th Cir.1995) (internal quotations and citation omitted), cert. denied, --- U.S. ----, 116 S.Ct. 1847, 134 L.Ed.2d 948 (1996); see also McFarland, 34 F.3d at 1512 ("While appellant correctly asserts that 'just cause' encompasses primarily physical incapacity or absence due to religious observance, the excusing of a juror who had previously advised the court and counsel of his lengthy vacation plans does not constitute an abuse of discretion."

Page 1194