The following excerpt is from U.S. v. Humeumptewa, 8 F.3d 31 (9th Cir. 1993):
We review for an abuse of discretion the district court's instructions to the jury. United States v. Cuozzo, 962 F.2d 945, 951 (9th Cir.), cert. denied, 113 S.Ct. 475 (1992) In reviewing an Allen instruction, "we consider whether the instruction, taken in its context, had a coercive effect." Id. We assess the coerciveness of a supplemental instruction by looking at "the form of the jury charge, the period of deliberation following the charge, the total time of deliberation, and other indicia of coerciveness or pressure." Id.
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