People v. Sargeant

Summary

The court held that a defendant may forfeit the constitutional right to a 12-person jury through egregious misconduct directed at a sworn juror after deliberations have begun. Because defendant deliberately confronted the jury foreperson at his home, causing the foreperson's discharge, and no alternate jurors remained, the trial court acted within its discretion by proceeding with 11 jurors rather than declaring a mistrial. The court also rejected defendant's federal jury-composition claim. No separate opinions were issued.