The following excerpt is from United States v. Erickson, 19-4337-cr (2nd Cir. 2021):
3. United States v. Simmons, 560 F.3d 98, 109 (2d Cir. 2009) (internal citation omitted); see, e.g., United States v. Walker, 974 F.3d 193, 209 (2d Cir. 2020) (concluding that the district court did not abuse its discretion "whenrather than declaring a mistrialit decided to dismiss a juror who advised the court that she had a nightmare after the close of the . . . trial" but before the verdict was reached).
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