Brasfield v. United States

In Brasfield v. United States, 272 U.S. 448 (1926), the jury indicated it was deadlocked after some hours of deliberation. The trial judge inquired how it was divided numerically. The foreman told the court that it stood nine to three, without indicating which number favored conviction. The Supreme Court declared that the inquiry itself is generally coercive and should be regarded as a ground for reversal. Id. at 450. The court concluded that "such a practice, which is never useful and is generally harmful, is not to be sanctioned." Id.