When will a jury be able to continue deliberations in a civil case?

9. We express no opinion on whether Cotey was in fact capable of continuing with the deliberations. It may have been that she was not, and that mistrial was the only viable option. But because it was reasonably possible that the problems all stemmed from the other jurors' disagreement with her position on the merits, it was error to continue the case without her. There are, of course, other means by which a district court can ensure that the seated jurors are capable of participating effectively in deliberations. Voir dire is the primary mechanism. See Dyer v. Calderon, 151 F.3d 970, 973 (9th Cir. 1998) (en banc).