What is the current state of the law on judicial review of juror bias at the end of a long trial?

^1. See Dyer v. Calderon (9th Cir. 1998) 151 F.3d 970, 972-973, 978-979, 985 (reversing convictions and sentences in capital case for failure to conduct adequate inquiry into corroborated report of possible juror bias at the end of long trial, acknowledging the "extremely delicate situation [presented in any case] when a juror is suspected of prejudice or misconduct," and the "difficult position" the trial judge faced in that case, with "five weeks of trial completed and a verdict in hand," but concluding that was no justification for inaction and "attribut[ing] the trial judge's complacency to an ostrich-like desire to avoid learning anything that would jeopardize the verdict").