Conviction undone by unexcused juror’s admitted bias

SAN FRANCISCO — The Ninth Circuit vacated one accused fraudster’s insider-trading conviction and remanded the matter for a new trial after he argued the California federal court refused to dismiss a juror for bias after he told the judge he wasn’t sure he could be impartial. The panel held that the juror came forward to express his own bias, so the court should have not delegated its responsibility to investigate the juror to the juror himself, who served for the remainder of trial.