How have the courts dealt with jury safety concerns?

The government successfully rebutted the presumption in this case. Kabir's argument to the contrary is not persuasive. The district court properly responded to the jurors' fears by individually questioning them and assuaging them of their safety concerns. See Sarkisian, 197 F.3d at 982 (holding that the district court "adequately dispelled any prejudice by telling the jurors in open court that the [perceived threat] was a prank, and by individually questioning the jurors to make sure that they could proceed impartially"). The court did not abuse its discretion in crediting the jurors' claims that they could be fair in their assessment of the case. See United States v. Stinson, 647 F.3d 1196, 1216 (9th Cir. 2011).