The court of appeals reversed a district court judgment and remanded the action with instructions. The court held that a California trial court violated a defendant’s Sixth Amendment right to a fair trial by jury by dismissing a juror in mid-deliberations where the juror was known to be the lone holdout for acquittal.

Tara Williams was charged in California state court with special circumstances murder and a firearm enhancement. She and a co-defendant were separately tried for the underlying murder.