Spruill v. United States

Issue: (1) Whether the Sixth Amendment permits a federal court to dismiss a deliberating juror (in particular, a known holdout for acquittal) based on alleged bias or sympathy for the defendant, where there is a reasonable possibility that the request for the juror's removal stemmed not from any bias but from her views on the sufficiency of the evidence; and (2) whether a defendant waives (rather than forfeits) a constitutional right where his counsel merely answers "yes" when asked whether he agrees with the court's decision at trial, in the absence of any evidence that counsel or the court recognized the possibility of a legal error, and in the absence of any plausible tactical benefit to failing to object.