In what circumstances will a jury be discharged from a trial for failing to reach a verdict?

In People v. Medina (1980) 107 Cal.App.3d 364, 370 (Medina), this court found the trial court abused its discretion where it discharged the jury after prematurely concluding the jury was deadlocked. In Medina, the jury notified the court that it was split six to six, and needed further instructions because there were unanswered questions. (Id. at p. 369.) Ten jurors indicated further deliberations would be fruitless. (Ibid.) The trial court declared a mistrial and discharged the jury without asking what instructions or further information it required. (Id. at pp. 369-370.) This court held that the trial court was in no position to conclude the jury was unable to reach a verdict, reasoning that a rereading of the evidence or the instructions may have facilitated a decision. (Id. at p. 370.)

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