FLIMSY EXCUSES FOR CAUSE: TWO OPPOSITE APPROACHES FROM THE BENCH
The following is excerpted from chapters one and five of Fixing the Engine of Justice: Diagnosis and Repair of Our Jury System. Chapter one deals with factors that contribute to a lack of representation in our jury system, including too-easy dismissals for cause. Chapter five includes recommendations for expanding the jury pool, one of which is the elimination of flimsy excuses for cause.
Norm Crosby, the comedian once said, “When you go into court, you are putting your fate into the hands of twelve people who weren’t smart enough to get out of jury duty.”Norm Crosby is a comedian from the Laugh-In generation that many younger readers won’t remember, but his cynicism on this issue isn’t entirely misplaced, and I would change “smart enough” to “determined enough.”
Following the test for financial hardship, the jury pool is further thinned when the judge invites jurors to offer other reasons why they cannot or should not serve on a jury. This process is usually completed in open court, so everyone can hear what excuses result in dismissal by the judge. For jurors who don’t want to serve, this is a terrific way to learn the best excuses. That’s not to say it’s all that difficult.
Consider the example of an executive for a large corporation who was in a Ventura County, California jury pool on a case I was retained on many years ago. When I say large, I mean a huge international corporation, a food giant with a well-recognized name. His reason for wanting to be excused was that he was working on a “big deal.” He claimed his corporation would suffer severely if he had to spend two weeks, the actual length of the trial, as a juror. Couldn’t anyone fill in for him for that brief period of time? Was he the only one at that multinational corporation who could do what he did? Couldn’t he accomplish anything in the evenings after trial? For that matter, as an executive for a big company, wouldn’t he pretty much always be working on a big deal? Isn’t that part of an executive’s job description? By that reasoning, neither he, nor executives from any large company, should ever have to serve as a juror.
Even the juror in question seemed amazed. He sheepishly offered the court his “big deal” story. As a reasonably good judge of nonverbal communication, it was obvious to me that he didn’t believe in his own cause. I think he was as stunned as I to hear it had worked, but the fact it did caused many jurors who hadn’t initially offered any reason for being dismissed to raise their hands for another chance. The judge proceeded to excuse so many from the first pool of jurors (about fifty) that a second batch had to be brought in to finally seat a jury of twelve.
DILBERT © UFS Reprinted by Permission
In the same courthouse some years later, the experience of one of my neighbors bears mentioning. He was in a pool of jurors he claimed numbered two hundred. This was the total recruit for the courthouse to fill jury seats in a number of cases starting on that day. All two hundred were questioned for one trial, but none were seated.
My all-time favorite example comes from a civil case in a Northern California federal court. The setup for this one includes the judge giving the following stirring, patriotic speech prior to voir dire:
I can tell you that I’ve talked to enough people who get summoned to jury service, and the universal reaction is, “Oh my God! I don’t want to do it! Let me get out of this any way I can.” And I talk to the jurors at the end of the case, after the case is over, and they tell me universally, “That was the most interesting, educational experience I’ve ever had.”
It was like having a vacation from work and being involved and learning about something new and different, and you’ve become a person who is of great service to our nation. Now, I realize that this is an inconvenience. I’m not, you know, naïve about it.
Many of you are involved with work and family things, and it’s an inconvenient thing to be summoned to jury service, but only citizens of the United States can sit as trial jurors. It is a privilege and a responsibility of citizenship.
The framers of our Constitution thought that jury service was so important and decisions of cases by jurors was so important that they wrote it into the Constitution. It’s a Sixth Amendment right to have cases decided by jurors. You know why? Because you represent sort of an extension of democracy. Our whole government is based on this, people participating in government.
Well, this court is a part of the judicial branch of government. How do we get people to participate in it? The jury. You represent the community, and so whenever questions of fact, that is, some dispute between parties that is something is right or wrong, whether the traffic light was green or red, those are questions or fact. And the founders of our country thought it was very important that ordinary citizens make that decision, not leaving it up to judges. There are things that I can do, but I cannot find the facts. That’s for you as citizens to do. That’s a very important principle of our government. And whenever we refuse to participate, we’re doing something that does violence to those democratic principles.
I’m sure you have watched, as I have, with the awakening of Eastern Europe to democracy—the dismantling of the Soviet Union—and they’re starting to have elections in those countries. People have been thirsty to participate in their government. They’ve been denied the right to sit as jurors or to vote. They’re thirsty to vote.
We have elections in our country, [and] people won’t bother to vote. If they register to vote, they don’t go out to vote. We have local elections, and 17 percent of the registered voters vote. That’s a small minority of the participants. If we’re going to lose our freedoms and liberties and democracy, it won’t be because we’re invaded by any country. It’s because, as citizens, when we receive a summons to participate in government, we say we don’t want it. We don’t want democracy. We want to live our own lives and let someone else do it. And that will be the downfall when more people refuse to participate that people say, “Look, it’s inconvenient I know, but I’m willing to do it.” And I urge all of you to take seriously your responsibility as citizens to step forward and serve.
I learned later, from the court reporter who sent me the transcript, that this is the judge’s standard speech – impressive. After the judge completed his voir dire, he invited the attorneys to ask questions, which they did before exercising their peremptory challenges. That left us with a jury of eight ready to be sworn in, or so we thought. At that point, His Honor interrupted the process by asking one final question. Following is the transcript of that portion of the proceeding:
Judge: All right. Now, before I let the others go, I want to make sure that you’re all delighted with your appointment to be jurors in this case, that you’re anxious to serve. But I started out this case saying who wants to be the juror, you would be the ones raising your hands, jumping up and down so that we would notice you because there are lots of people who are disappointed that they’re not sitting in those seats … And I’ve often had the case where I’ve finished selecting the jury and someone says, “I forgot to tell you that it’s really a problem for me.” So, I want to know now if any of you have any reason why you wish to not serve as jurors in this case? Excellent. Whoops! I knew I should have waited.
Allow me to interrupt His Honor for a moment. Why did the judge ask the question? Everyone with a hardship should have already declared it. Real hardships occur to people really quickly. So now he sees a hand raised. See if you can detect the level of urgency in the woman’s words:
Prospective Juror: Well, it’s kind of—I just realized my daughter just returned from college. And she’s looking for employment, and we only have one car. And if she does get a job, it would be a problem, you know, with transportation.
Judge: All right. What did she graduate in?
Prospective Juror: Pardon me?
Judge: Where did she graduate from?
Prospective Juror: She’s a sophomore at Duke University, but she’s looking for summer employment. She has an interview tomorrow. I would really like to do this, but I’m wondering, you know, especially with looking at the times. And if she does get employment with having one car available, it would be … it might be pretty difficult. She might not be able to accept the job because of … I intended to buy a car in about a couple of weeks, an extra car so that she could take [it] back to school eventually, but—
Judge: Well, now, those are the kinds of problems that come up, and you may or may not work it out. I just don’t want you to accept a position as a juror and find yourself in a circumstance where that becomes a burden on you. Now, it could be she won’t get a job. I hope that’s not the case, but it could be she would get a job where she could drop you off and pick you up, or it could be that other transportation arrangements could be made. But this is the time to indicate if you would find that prospect of being the only driver of the only car to be something that … where you say I think I will have a hardship for that reason.
Prospective Juror: It could be.
Judge: Well, it’s got to be definite. It could be, I know. Do you wish to be excused?
Prospective Juror: That’s a tough one. Yes, I guess so.
It should be remembered that the woman’s daughter attends Duke, not one of your low-cost institutions, and it should also be understood this trial was taking place in a large northern California city with a superb public transportation system.
In this case, a juror was excused for hardship simply because serving would have been a minor inconvenience. The examples I’ve cited are not aberrations. They are extremely common. Why? The fault lies entirely with the bench.
I’ve observed that judges often want to be pals to jurors. They want jurors to identify with them. They don’t want disgruntled jurors, and they don’t want to be the bad guy who forces the unhappy prospect to do his or her civic duty. The attorneys are powerless in this situation. In practice, they can’t appeal to the judge to deny the individual’s wish to be excused. The attorney who did so would immediately alienate the juror to his cause, not to mention the judge. The effect is that many qualified jurors are exempted from service, thinning what is often already a thin population.
The Supreme Court has weighed in on this issue, as shown in the Court’s majority opinion in Thiel v. Southern Pacific (excerpted below), when they found the trial court had violated California Code of Civil Procedure, 201. It’s a good code and should be the law of the land (my emphasis below).
And under the state [California] law, “A juror shall not be excused by a court for slight or trivial causes, or for hardship, or for inconvenience to said juror’s business, but only when material injury or destruction to said juror’s property or of property entrusted to said juror is threatened” … Jury service is a duty as well as a privilege of citizenship; it is a duty that cannot be shirked on a plea of inconvenience or decreased earning power
In my practice, I have been frustrated by judges like the ones quoted in Part I of this article who allowed hardship excuses for the flimsiest of reasons. I’d like to see more examples of a fate similar to that of an Athens, Georgia, woman who was sentenced to two days in jail for avoiding jury service by lying about her father dying.
One of the recommendations I make in the book is to sequester the voir dire so that jurors do not get a tutorial on how to get out of jury service from those who precede them in the process. Absent that, actions similar to that of a judge in Massachusetts would send a pretty strong message to the rest of the jury pool.
Judge Gary Nickerson of the Barnstable, Massachusetts Superior Court told prospective juror Daniel Ellis, “In thirty-two years of service in courtrooms, as a prosecutor, as a defense attorney and now as a judge, I have quite frankly never confronted such a brazen situation of an individual attempting to avoid jury service.” On a questionnaire the potential jurors had completed, Ellis wrote that he didn’t like homosexuals and blacks.
“You say on your form that you’re not a fan of homosexuals,” the judge said.
“That I’m a racist,” Ellis interrupted and then added, “I’m frequently found to be a liar, too. I can’t really help it.”
“So, are you lying to me now?” asked the judge.
“Well, I don’t know. I might be,” Ellis responded.
“I have the distinct impression that you’re intentionally trying to avoid jury service,” said Nickerson.
Ellis answered, “That’s true.”
Whereupon Judge Nickerson ordered Ellis taken into custody.
Compare the previous example of voir dire with the one below. It’s from a state court case I worked on in Los Angeles. The judge is the Honorable Carl J. West of the Complex Case Division, since retired. I’ve included his name because he deserves the credit, but I’ve withheld the full names of the prospective jurors for their privacy.
To begin with, the judge swore the jurors in prior to voir dire. As you will read, unlike the part I example, this judge holds people accountable for their duty to the system. I have deleted some text just to move it along a little faster and to protect identities. Otherwise the transcript below is verbatim. I have picked it up at the point where the judge, having sworn in the panel before voir dire, dealt with hardship excuses.
Judge West: Ok, I’m going to go through hardship issues … but we’ll do it so that those of you who truly have a hardship, which is a justification for my excusing you, will not have to come back tomorrow. We try and make this as user friendly as possible; it doesn’t always work.
The first thing you need to know is the fact that you were cleared to come to this courtroom means that, in effect, there’s a presumption that you are able to serve in this trial. Financial hardship alone may not be a justification for excusing you. Personal matters … work-related restrictions are not necessarily a basis for excusing you for hardship. We have what is known as a one-trial one-day service program here. You come in; if you are selected to serve on a jury, you must serve for that trial. If you are not selected the one day that you are here, or, in your case, it’s going to be probably two days, is the end of your service for a year.
That puts demands on our system. We have about ten thousand jurors a day in the Los Angeles Superior Court system. Ten thousand a day, you can do the math. We barely have enough people in the county to bring in the number we need all the time to make our courts run. And so you may feel that my willingness to excuse you for a hardship is kind of stingy or a little arbitrary, but you have to keep in view and keep in mind the global needs of the system; the fact that it’s essential we have jurors like each one of you who bring a cross section of the community into the courthouse to decide the matters that come before the court.
And those are all the apologies I can give right now. But I will certainly entertain all of the concerns that you have. So, in the front row right here, please state your name and then tell me what your hardship is.
Prospective Juror Shane: My name [is] Shane. I don’t have an actual hardship or reason not to come, but just tomorrow I have a doctor’s appointment. From there out, I’m okay. And the doctor appointment is about at eleven thirty.
Judge West: All right. Well, you are going to be here at eight thirty, and we’ll do our best to accommodate you. If I can’t, you may have to reschedule. And I realize that’s a burden too, but when I have thirty-five people here, sir, I’m always going to have people with conflicts. And while I don’t mean to be insensitive, and I know how long sometimes you have to wait to get an appointment, the process just doesn’t work. And let me just suggest that if every time someone has a conflict we have to stop the trial and wait for somebody to take care of their personal business, we’d never get anything done. And so you have to be a little harsh at times, and I just hope that you appreciate that. Yes, ma’am?
Prospective Juror Sherilyn: My name is Sherilyn. And I am self-employed, and I’m single. And it would be difficult for twelve days [the projected length of the trial].
Judge West: What type of work do you do?
Prospective Juror Sherilyn: I’m a realtor.
Judge West: OK. Thank you. Next?
Prospective Juror Arman: I’m Arman. I’m also self-employed. I’m under contract. I’m working on measure Y for Santa Paula. It’s like deadline-oriented stuff. I’ve got deadlines. At two o’clock today, I’ve got to get the brochures out. If I don’t make it, they are going to sue me, and I’m going to be in a whole lot of trouble.
Judge West: You are self-employed, sir?
Prospective Juror Arman: I am self-employed, a one-man team.
Judge West: Well, the sooner I get you out of here, the better chance you have of meeting your deadline by two o’clock. Anyone else in the front row?
Prospective Juror Katherine: My name is Katherine. The only reason I’m just concerned with about staying for twelve days is on the eleventh of April I have [a] hearing for work. It’s for work. It’s a Cal-OSHA hearing that I have to attend to, but that’s the only thing I’m really worried about is finishing.
Judge West: Okay, ma’am. Thank you. Anybody else?
Prospective Juror Nindi: My name is Nidi. I’m self-employed. I service vending machines, and I believe twelve days will be a little hard on the amount of money I’m taking.
Judge West: Okay. Thank you, sir. Anybody else in the back row.
Prospective Juror Young: My name is Young. Yesterday I told the lady I can’t speak English well. I can—why I’m here now, I don’t understand. My English is short.
Judge West: Okay. Sir, have you understood what I’ve told you so far?
Prospective Juror Young: Pardon me?
Judge West: Have you understood what I’ve told you so far this morning?
Prospective Juror Young: No. My house is near here.
Judge West: Okay. How long have you—what type of work do you do, sir? Do you work?
Prospective Juror Young: Yeah, I work?
Judge West: What kind of work?
Prospective Juror Young: What kind? Like UPS … courier.
Judge West: I thought you said accordion repair. And I thought that was a little unusual.
Prospective Juror Young: Many times I told the staff so they told I don’t understand.
Judge West: All right. Thank you, sir. Thank you. Anyone else in the back row?
Prospective Juror Ken: My name is Ken, and I don’t work for a great company. It’s called [name withheld], and I’m expendable. You know, these companies, you are expendable. I’m a photographer. I take pictures of cars, and if I don’t, you know, show up for maybe a week, they are going to replace me. So I could lose my job, realistically, because this company doesn’t pay for nothing. I asked, “Do you pay for jury duty?” He goes, “No, we don’t.”
Judge West: How long have you worked for them, sir?
Prospective Juror Ken: About ten years. So, basically they say, “Hey, look, you know, you know, we might have to find somebody else. It’s possible. We’ve got to get the job going.” You know how it is?
Judge West: I understand.
Prospective Juror Ken: So, you know, I can’t work twelve or however days. They might find somebody else by the time I come back. It can be gone and—
Judge West: Have a seat, sir. Thank you.
Prospective Juror Saudia: My name is Saudia. The first part is I am undergoing physical therapy right now, three days a week, which is kind of crucial to my type of employment. I’m a dance teacher. So I’m kind of at a point where it’s crucial that I attend to continue my improvement. The second part is, because I’m a dance teacher, I’m kind of project-oriented toward a show. And I only see the kids and some other students once a week. So as far as twelve days, it would kind of hamper the whole deadline for my teaching them.
Judge West: Where do you teach, ma’am?
Prospective Juror Saudia: In La Canáda.
Judge West: In a private school or a public school?
Prospective Juror Saudia: It’s a private studio, but I also have other teaching engagements that I have with adults and so forth.
Judge West: All right. Thank you, ma’am. Anyone else?
Prospective Juror Tiffany: My name is Tiffany. It’s not for sure, but there’s a possibility I may have to go to New York for work on the third. I work for (name withheld), which is a fashion company. And we go into market five times a week, which is when we see the department stores and stores who buy the product, and that’s next week. And I don’t know today, but there’s a possibility—
Judge West: Let me just say, ma’am, that work-related obligations are not the types of obligations for which I can excuse you. Your inability to attend a show or an opening or something in New York for your employer is really your employer’s problem, and you have to understand that. Anyone else?
Prospective Juror Rosemary: My name is Rosemary, and the firm I work for (name withheld) only pays for ten days jury service, and I’m already on day two, so I would only have like eight more days with pay. And I have a mortgage and a lot of personal expenses and credit card bills. I don’t have a husband. I’m single. And even, let’s say, go to three days without my paycheck could be devastating for me because I go from check to check. I really need to get my full salary and not go beyond the eight more days that I have.
Judge West: All right, ma’am.
Prospective Juror Rosemary: Thank you.
Judge West: Let me just say, on all of these pay policies, I am more than willing to call supervisors, call your firms, and explain to them the need for you to participate if you are selected as a juror. Sometimes we worry too much about these things up front. I have thirty-five people here. We’re only going to pick twelve jurors and three alternates. And so a lot of you will be gone when the process is done. But once we get down to the jury being sworn and a panel that’s going to be with us, I will do everything I can to assist you so that you don’t incur the hardship. And we will even try and adjust our schedule if absolutely necessary to accommodate an irreconcilable conflict.
But all of that said, we still need to move forward. And jury service is really an obligation of citizenship and not something that is voluntary, as you might like to have it. So if that sounds a little heavy-handed, again, I’m always giving apologies, but we have to make the ship run here, and the only way it runs is with people like yourselves that serve as jurors. Anybody else in the front row.
Prospective Juror Rob: I’m Rob, and I know this is work-related, but I have an individual, a coworker who is going to be absent, that I am their cover for on April 10, 11, and 12. I am their sole cover, and that’s my reason for requesting the excuse.
Judge West: What kind of work do you do, sir?
Prospective Juror Rob: I work for an insurance company.
Judge West: Insurance companies are regular participants in the court process. And they need to support us just as we support them every day. And so while I’m sympathetic, your company is going to have to find some way to cover this problem if you are selected as a juror in this case. Let’s start left side back row.
Prospective Juror Cwenne: Hi, my name is Cwenne, and I work for a very small firm. One of our coordinators was recently called out of the office on a family emergency so I’m covering for her. And also our firm does not pay. It doesn’t pay any jury duty days off. So it’s a financial hardship for me as well.
Judge West: What type of work is it, ma’am?
Prospective Juror Cwenne: It’s a real estate investment development company.
Judge West: The name of the firm?
Prospective Juror Cwenne: [name withheld]
Judge West: And what type of work do you do, ma’am?
Prospective Juror Cwenne: I’m a project coordinator.
Judge West: All right. Thank you. Yes, sir?
Prospective Juror Tom: My name is Tom. I employ twenty-three people. I’m involved in ongoing negotiations all the time with our suppliers and our customers. And taking me out of there for twelve days is going to be a hardship on the business. And I fear for, not myself, but my employees.
Judge West: What type of business is it?
Prospective Juror Tom: It’s a radio syndication marketing production.
Judge West: Okay. Let me just explain, ladies and gentlemen, when this one-trial/one-day process came in, historically people were routinely excused from jury service without a lot of questions asked; doctors, lawyers, professionals, quite frankly, some of those people could better afford to serve as jurors and take the loss than the wage earner and the hourly employees like many of you on both ends of the spectrum here. We have tightened that up with one day/one trial. People are not excused routinely. And the burdens are substantial. And we are the first to recognize them, but it’s hard to be fair when you excuse the doctor or the lawyer or the owner of a business, but you don’t excuse the person who has $750 a month apartment payment and makes $8 an hour and works every day. And there really isn’t a financial analysis that works in this process. I mean, we basically have to take a pretty hard line on financial reasons for not serving. And I only say that so you can appreciate where we may be going here. Anyone else in the back row? Yes, ma’am.
Prospective Juror Joan: My name is Joan H. I’m a single mom of three children, and my employer pays zero jury duty pay, but if you are willing to call them, I’m willing to stay.
Judge West: Okay. I’ll certainly make the call. And there are no promises because a lot of people won’t even listen to me, but I’ve been fairly successful in helping people that have a problem. Yes, ma’am.
Prospective Juror Jonette: My name is Jonette. I work for a very small company. I work for (name withheld). It’s family oriented. I’m the only one that’s not family. There [are] only two other people in the office. My boss pays for a couple days. Even if you call, I’m going to have a hard time. He’s just a jerk.
Judge West: My condolences, ma’am. How long have you worked for him?
Prospective Juror Jonette: I’ve worked there a little over five years. It’s hard because it’s close to home.
Judge West: All right. And do we have somebody else in the corner? Yes, ma’am.
Prospective Juror Gilda: I’m Gilda. I have high blood pressure, and I am on three pills. And one pill acts like a diuretic because it put me in the bathroom every now and then, just like before coming in I went to the bathroom and now I feel like going again.
Judge West: We take regular breaks. You will always have an opportunity.
Prospective Juror Gilda: And seven months ago, I fractured my left foot. And if my foot is dangling more than two hours, it gets swollen, and I find it hard to walk.
Judge West: Do you work, ma’am?
Prospective Juror Gilda: No, I’m retired.
Judge West: Okay. What kind of work did you do before you retired?
Prospective Juror Gilda: Registered nurse.
Judge West: All right. Thank you, ma’am. Back here in the corner?
Prospective Juror Lori: My name is Lori, and I’m a sales director. So basically my income is based on whether I bring in business.
Judge West: Who do you work for, ma’am?
Prospective Juror Lori: [name withheld]
Judge West: Do they have a policy?
Prospective juror Lori: They do.
Judge West: What is their jury service policy?
Prospective Juror Lori: It’s three weeks, but if I don’t sell then, I mean, that’s pretty much what I’m employed to do is sell. And this is the selling season.
Judge West: But you are paid three weeks on a base salary basis?
Prospective Juror Lori: Yes, I get a salary, but—
Judge West: All right, ma’am.
With a stipulation from the attorneys on each side, prospective juror Young, the fellow whose English was “short,” was excused. The only other hardship excuses Judge West granted were Saudia, the dance teacher who was undergoing physical therapy three days a week, and Gilda, the woman with two medical conditions. He did not excuse the following:
- Shane, who had a doctor’s appointment
- Sherilyn, the realtor
- Arman, the self-employed PR guy who makes brochures and was going to get sued if he didn’t meet his deadline
- Katherine, the woman who had a Cal-OSHA meeting but wasn’t really trying to get out of jury service
- Nindi, the vending machine service person who probably really would have a financial hardship
- Ken, the “expendable” car photographer for a company that doesn’t pay for jury service and told him he might lose his job
- Tiffany, the woman who works for a fashion company who had a trip to New York coming up
- Rosemary, the woman with only eight days left on her jury service pay and for whom the extra days without pay would have been “devastating”
- Rob, the guy covering for someone else at work, an insurance company
- Cwenne, who works for a real estate investment development company that does not pay for jury service
- Tom, who owns a company employing twenty-three people that can’t survive without him
- Joan, the single mom who works for a company that doesn’t pay for jury service but was willing to stay if the judge would call her employer
- Jonette, who works for a small company owned by a “jerk”
- Lori, the sales director who works on commission but also has a base salary from a company that pays for three weeks of jury service
Did Judge West seem harsh to you? Not to me. He wasn’t trying to be the jury’s buddy. He was always firm but polite and respectful. He was also sympathetic, but in the end, he did exactly what he had to do to make the system work, a system that he agrees is based on jury service as an obligation of citizenship.
What I particularly liked about the judge was his consistency. He said he would not excuse anyone for a financial hardship, and he didn’t. His only excuses were for one man’s inability to speak English well enough and for two women who had medical conditions. I also appreciated his repeated explanations of why he had to be so heavy-handed, if that’s what the perception was.
If that voir dire had taken place in the courtroom of the federal judge in chapter 1 or in many other courtrooms in America, most of those people would probably have been excused, and the system would have been out all the effort and tax dollars spent summoning them.
The way it works in Judge West’s courtroom is the way it’s supposed to work. That said, the very real hardship situations many of those prospective jurors shared are the reasons changes need to made in the system, some of which I propose in Fixing the Engine of Justice: Diagnosis and Repair of Our Jury System.
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 “US Supreme Court, Thiel v. Southern Pac. Co., 328 US 217 (1946),” Findlaw.com, March 11, 1999.
 “Dying-Father Excuse Lands Prospective Juror in Jail,” Los Angeles Times, May 9, 2000.
 “Jury duty excuse: I’m a racist, homophobic liar,” Associated Press, August 1, 2007.
 City of Norwalk vs. Five Point U-Serve, Los Angeles County Superior Court, 3/28/2006, case # 038298