California, United States of America
The following excerpt is from People v. Romero, 14 Cal.App.5th 774, 222 Cal.Rptr.3d 322 (Cal. App. 2017):
People v. Wheeler (1978) 22 Cal.3d 258, 273274, 148 Cal.Rptr. 890, 583 P.2d 748.) A sitting juror's actual bias that would have supported a challenge for cause also renders the juror unable to perform his or her duties and thus subject to discharge. ( People v. Keenan (1988) 46 Cal.3d 478, 532, 250 Cal.Rptr. 550, 758 P.2d 1081.)
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