In what circumstances will a jury not be able to reach a unanimous decision in a case?

Here, however, the court was at pains to dispel any such inference. The court neither insisted that a deadlock be resolved, nor urged minority jurors to give special attention to majority views, nor suggested that failure to reach a decision would have any specific consequences. (Cf., e.g., People v. Gainer (1977) 19 Cal.3d 835, 847-852, 139 Cal.Rptr. 861, 566 P.2d 997.) On the contrary, it reinstructed on the broad scope of the jury's sentencing discretion, including its power to exercise leniency even if aggravating circumstances outweighed mitigating. Moreover, the court repeatedly cautioned that no juror should surrender his individual judgment and conscience, even if this meant no unanimous decision could be reached. ²⁷

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