State of New Jersey, Plaintiff-Appellant v. Michael Ross II, Defendant-Respondent

Summary

The Supreme Court held that, absent any indication that jurors had reached factual findings, a trial judge may issue a Czachor charge after a deadlock and may substitute an alternate juror for an ill juror without committing plain error, reversing the Appellate Division and reinstating the convictions. The Court overruled State v. Banks to the extent it barred such substitutions. Judge Cuff dissented, arguing the substitution was improper and would have affirmed the Appellate Division.