McKay v. State, 61 So. 3d 1178

McKay was charged with selling cocaine within 1000 feet of a school.
During voir dire, defense moved to strike juror A.F. for cause due to potential bias against McKay if he did not testify.
A.F. indicated a desire to hear from McKay and asked to speak privately; he later stated biases favoring conviction if the State’s case is credible and McKay does not testify.
The trial court denied the cause strike; defense used a peremptory challenge on A.F. after the denial.
McKay’s defense exhausted peremptory challenges; the court granted one additional peremptory against juror eleven only, then denied further requests.
Jury found McKay guilty; defense reserved objections until after trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion denying strike for cause	McKay	State	Yes; A.F.'s responses created reasonable doubt of impartiality.
Whether denial of additional peremptory challenge was error	McKay	State	Not dispositive; remand for new trial based on cause-strike error.

Pentecost v. State, 545 So.2d 861 (Fla. 1989) (abuse-of-discretion standard for denial of challenge for cause)
Leon v. State, 396 So.2d 203 (Fla. 3d DCA 1981) (standard for determining juror competence; manifest error if equivocal answers)
Puiatti v. Dugger, 589 So.2d 231 (Fla. 1991) (juror impartiality considerations; preservation of error)
Miller v. State, 934 So.2d 580 (Fla. 3d DCA 2006) (review of juror impartiality and rehabilitation attempts)
Hall v. State, 682 So.2d 208 (Fla. 3d DCA 1996) (impartiality concerns in voir dire context)
Turner v. State, 645 So.2d 444 (Fla. 1994) (impartiality when State's burden and defendant's silence are involved)
Sydleman v. Benson, 463 So.2d 533 (Fla. 4th DCA 1985) (close cases favor excusing jurors to preserve impartiality)
Price v. State, 538 So.2d 486 (Fla. 3d DCA 1989) (reliance on juror candor and impartiality in decision)