Fields v. State
Fields v. State, 487 P.2d 831 (Alaska 1971) involved a "verdict-urging" instruction similar to the so-called "Allen charge" that was given a jury that was deadlocked after two days of deliberation.
The supreme court found two reversible errors with the instruction.
First, the instruction improperly emphasized the duty of the minority jurors to reconsider their views without a like admonition to the majority. The court ruled that this error made the instruction so "inherently fraught with coercive tendencies that its use cannot be justified."
Second, the instruction ordered the jury to deliberate until it reached a unanimous verdict. The supreme court ruled that "such a requirement is clearly contrary to our law."