United States v. Della Porta

OPINION

SILVERMAN, Circuit Judge:

In United States v. Evanston, we recently held that a district court abuses its discretion and impermissibly coerces a jury verdict where, “over defense objection and after the administration of an unsuccessful Allen charge, [the court] inquire[s] into the reasons for a trial jury’s deadlock and then permit[s] supplemental argument focused on those issues, where the issues in dispute are factual rather than legal.” 651 F.3d 1080, 1082 (9th Cir.2011). In this case we also address the use of supplemental closing arguments to assist a deadlocked jury, but under…