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The article discusses the conflict between the temporarily unavailable juror and the mandatory 24-hour limit on the separation of jurors in New York State during deliberations. It also discusses the historical origins of jury sequestration. New York law required juries in 1995 to be sequestered from the time they started deliberations until they reached a verdict. The mandatory sequestration rule was relaxed with the enactment of Criminal Procedure Law Section 310.10(2).

The article explores the conflict between the temporarily unavailable juror and the mandatory 24-hour limit in the state of New York on the separation of jurors during their deliberations. It presents the historical origins of jury sequestration. The remedy of an automatic mistrial and the right of a defendant to have a fair trial under the Sixth Amendment of the Constitution are discussed, as well as the relevance of case law to the New York Criminal Procedure Law (CPL).