A MANUAL OF JURY TRIAL PROCEDURES - 2004
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Chapter Two: Jury Selection

2.8     Challenges for Cause
          A. In General
          B. Erroneous Overruling of Challenge for Cause Cured by Exercise of Peremptory Challenge

A MANUAL OF JURY TRIAL PROCEDURES - 2004

A.    Challenges for Cause: In General

The number of prospective jurors who may be challenged for cause is unlimited. 28 USC 1870. However, situations in which a challenge for cause can be used are "narrowly confined to instances in which threats to impartiality are admitted or presumed from the relationships, pecuniary interests, or clear biases of a prospective juror." Darbin v. Nourse, 664 F.2d 1109, 1113 (9th Cir. 1981).

A MANUAL OF JURY TRIAL PROCEDURES - 2004

If a defendant, by exercising a peremptory challenge, cures the erroneous denial of a challenge for cause, the defendant has been deprived of no rule-based or constitutional right. See United States v. Martinez-Salazar, 528 U.S. 304, 307 (2000). Moreover, a defendant's exercise of peremptory challenges pursuant to Rule 24(b), Fed. R. Crim. P. is not denied or impaired when the defendant chooses to use a peremptory challenge to remove a juror who should have been excused for cause. Id. at 317.