The Supreme Court today unanimously reverses the conviction and death penalty in People v. Armstrong because the trial court improperly discharged a juror for failing to deliberate regarding the defendant’s guilt. Applying a heightened standard of review and “remind[ing] trial courts that the removal of a seated juror for failing to deliberate is a serious matter that implicates a defendant’s state and federal constitutional right to a unanimous decision by the jury,” the court’s opinion by Chief Justice Tani Cantil-Sakauye concludes reversal is required because the discharged juror’s “inability to perform her duty as a juror does not appear in the record as a demonstrable reality” and is not “‘manifestly supported’ by th[e] evidence.” However, the court rejects the defendant’s contention that the trial court should have severed three sets of charges against him.