What is the test for determining whether a prospective juror has a valid reason to be excused?

California, United States of America


The following excerpt is from People v. Arias, 13 Cal.4th 92, 51 Cal.Rptr.2d 770, 913 P.2d 980 (Cal. 1996):

17 As will be recalled, the trial court found, among other things, "that for the reasons that you've stated that you were justified in exercising a peremptory challenge," and "that ... all [excusals were] justified under the circumstances from the questions given." Citing People v. Fuentes, supra, 54 Cal.3d 707, 286 Cal.Rptr. 792, 818 P.2d 75, defendant urges that the trial court's ruling was fatally incomplete because it failed to address every excused juror individually. Fuentes is distinguishable. There, the trial court upheld the excusal of several prospective jurors even though it concluded, in general terms, that some of the reasons given for their dismissal were true and some were false. Under those circumstances, we held, the court must determine that there were genuine reasons for each individual suspect excusal. (Id., at p. 720, 286 Cal.Rptr. 792, 818 P.2d 75.) Here, by contrast, the court's ruling implied that it found all the reasons applicable to each juror to be true. Nothing more is required.

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