In United States v. Martinez-Salazar, 528 U.S. 304 (2000) the criminal defendant sought to remove a potential juror for cause and the district court denied the for-cause challenge. Martinez-Salazar, 528 U.S. at 315. Martinez-Salazar then utilized one of his peremptory challenges rather than permitting the objectionable juror to sit on his jury. Id. Notwithstanding, he was convicted. On appeal Martinez-Salazar claimed the erroneous denial of his for-cause challenge forced him to waste one of his peremptory challenges on a juror who should have been removed for cause. Id. The Supreme Court disagreed: "The District Court did not demand--and Rule 24(b) did not require--that Martinez-Salazar use a peremptory challenge curatively. In choosing to remove Gilbert rather than taking his chances on appeal, Martinez-Salazar did not lose a peremptory challenge." 528 U.S. at 315-16. The Court noted that had the district court's ruling resulted in the seating of a juror who should have been removed for cause, the proper remedy would be reversal. Id. at 316. However for better or worse Martinez-Salazar effectively eliminated that possibility when he exercised his peremptory challenge to remove the objectionable juror. In United States v. Martinez-Salazar, the defendant and a co-defendant were charged with a variety of federal offenses. During the jury selection process, a prospective juror indicated several times that he would favor the prosecution. The co-defendants challenged him for cause, but the district court refused to excuse him. The defendant then used a peremptory challenge to remove the prospective juror. The co-defendants subsequently exhausted all of their peremptory challenges. Following his conviction, the defendant complained on appeal of the district court's refusal to strike the prospective juror for cause. The Ninth Circuit Court of Appeals held that the district court had abused its discretion, and that the District Court's mistake resulted in a violation of Martinez-Salazar's Fifth Amendment due process rights because it forced him to use a peremptory challenge curatively, thereby impairing his right to the full complement of peremptory challenges to which federal law entitled him. It held that such an error required automatic reversal. Martinez-Salazar, 528 U.S. at 307-10. However, the Supreme Court reversed, holding that a defendant's exercise of peremptory challenges pursuant to the federal rules of criminal procedure is not denied or impaired when the defendant chooses to use such a challenge to remove a juror who should have been excused for cause. Martinez-Salazar, 528 U.S. at 315-317. The Court found that the primary rationale for peremptory challenges in federal court was the same as in Oklahoma courts: "to help secure the constitutional guarantee of trial by an impartial jury." Martinez-Salazar, 528 U.S. at 316.