In People v. Compton (1971) 6 Cal. 3d 55, Justice Mosk wrote that "since our decision in People v. Hamilton , the trial court has at most a limited discretion to determine that the facts show an inability to perform the functions of a juror, and that inability must appear in the record as a demonstrable reality. Here the ambiguity in the juror's remarks was never resolved by proof, and the court was not entitled to do so by presuming the worst. Such a presumption, however well motivated, does not furnish the 'good cause' required by the governing statutes." ( Compton, supra, at p. 60.) The Compton opinion thus marks the first appearance in California case law of the phrase "demonstrable reality" to describe the quantum of proof required to sustain on review a trial court's order removing a sitting juror for misconduct. The phrase (and the test it describes) has since become a shibboleth in our juror misconduct jurisprudence.