The following excerpt is from Ellis v. Biter, Case No. 1:17-cv-01443-DAD-JDP (E.D. Cal. 2020):
inherent. Tinsley v. Borg, 895 F.2d 520, 527 (9th Cir. 1990). Although courts "should hesitate before formulating categories of relationships which bar jurors from serving in certain types of trials," if the nature of the relationship and circumstances make it "highly unlikely that the average person could remain impartial in his deliberations under the circumstances," a finding of implied bias may be appropriate. Id.
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