Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)

Citation: Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)
Parent Document: Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)
Jurisdiction: United States (federal)
Effective Date: 2018-05-30
Original Source: https://www.courtlistener.com/opinion/4502306/heriberto-rodriguez-v-county-of... ↗

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We have found implied bias based on a juror’s
employment only where it has been accompanied by
additional factors. In United States v. Allsup, 566 F.2d 68,
71–72 (9th Cir. 1977), we held that two jurors were impliedly
biased in a bank robbery trial where they worked for a
different branch of the bank that had been robbed. We
attributed this result to “[t]he employment relationship
coupled with a reasonable apprehension of violence by bank
robbers.” Id. In a subsequent en banc opinion, we noted the
limits of Allsup’s holding, explaining that “[t]he implied bias
that we found in Allsup was based on the jurors’ direct
                    RODRIGUEZ V. CRUZ                       51

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