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Since the adoption of the 1983 amendment, federal courts have exercised their unilateral authority to dismiss jurors during the course of deliberations for a variety of reasons. Often, courts employ Rule 23(b) in cases, like those described in the Advisory Committee Note, where a juror is incapacitated or has otherwise become unavailable during the course of deliberations. See, e.g., Reese, 33 F.3d at 172-73 (juror leaving for business trip); United States v. Wilson, 894 F.2d 1245, 1249-51 (11th Cir.) (juror became ill), cert. denied, 497 U.S. 1029, 111 L. Ed. 2d 792, 110 S. Ct. 3284 (1990); United States v. Armijo, 834 F.2d 132, 134 (8th Cir. 1987) (juror in car accident), cert. denied, 485 U.S. 990, 99 L. Ed. 2d 507, 108 S. Ct. 1297 (1988); United States v. Molinares Charris, 822 F.2d 1213, 1222-23 (1st Cir. 1987) (juror was 'nervous and upset,' had been crying during deliberations, and had taken tranquilizer); United States v. Stratton, 779 F.2d 820, 830-31 (2d Cir. 1985) (juror unable to deliberate on religious holiday), cert. denied, 476 U.S. 1162, 90 L. Ed. 2d 726, 106 S. Ct. 2285 (1986). 

'Just cause' is not limited ...

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