People v. Carrillo

Judge ROTHENBERG,

specially concurring.

Although I conclude there was no gross abuse of discretion in the trial court’s denial of defendant’s challenge to a potential juror, I view this one ruling as being precipitously close to requiring reversal. I write separately because denials of for-cause challenges to prospective jurors in criminal cases are becoming a recurring, and perhaps avoidable, appellate issue.

Recently, another divided panel of this court addressed a similar situation. There, the trial court, over the objection of both counsel, denied defendant’s challenge for cause tó another…