A shooting and drowning nearly three miles off the California coast sends the Ninth Circuit on a 200-year tour of federal maritime jurisdiction. The takeaway: Uncle Sam can prosecute murder on the high seas. But the conviction couldn't stay afloat. The district court improperly dismissed a holdout juror whose mental health crisis stemmed from pressure by fellow jurors to reach a verdict in the 12-day trial with three days of deliberations. With the jury-room dynamics at the root of the crisis, a mistrial (not dismissal of the juror) was the only proper course. “The alternative—permitting dismissal when a majority’s pressure eventually succeeds in incapacitating a dissenting juror—would give jurors perverse incentives and undermine the jury right enshrined in our Constitution,” the court wrote.
The case is United States v. Le, 23-1814 (9th Cir. Oct. 15, 2026).
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