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Ninth Circuit
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United States v. Sanchez — Ninth Circuit Adopts ‘Heavy Presumption of Prejudice’ Standard When Racially Biased Juror Is Removed Mid-Deliberation

The Ninth Circuit holds that when a racially biased juror is discovered and removed before a verdict is accepted, courts must apply the Remmer framework’s heavy presumption of prejudice—and reverses a tax-fraud conviction because the government could not rebut that presumption.

Ninth Circuit
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United States v. Cabrera Ramirez — Ninth Circuit affirms § 1326(d) collateral attack denial where defendant could not show prejudice from immigration counsel’s errors

Ninth Circuit affirms the Central District of California’s refusal to dismiss an illegal reentry charge under 8 U.S.C. § 1326(d), holding that even assuming ineffective immigration counsel, the defendant’s extensive criminal record and lack of rehabilitation made it implausible that he w

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