State of New Jersey, Plaintiff-Appellant v. Rafael Valenzuela Defendant-Respondent

Summary

The Supreme Court of New Jersey affirmed the Appellate Division's reversal of Valenzuela's conviction, holding that the trial court abused its discretion in discharging a juror under Rule 1:8-2(d) because the record did not clearly show the juror was personally unable to continue. The Court emphasized that a juror may be removed only for reasons strictly personal to the juror and not stemming from interactions with other jurors.