On April 21, 2026, a Ninth Circuit panel vacated an insider trading conviction in United States v. Bolandian, holding that the trial court failed to properly investigate a juror who admitted he was “not sure” he could remain impartial. The case involved a Los Angeles trader accused of profiting from confidential merger tips, resulting in a conviction and 24-month sentence. But on appeal, the court found plain error in allowing the uncertain juror—who ultimately served as foreperson—to remain without further inquiry. Emphasizing the court’s independent duty to ensure juror impartiality, the decision underscores that even without a defense objection, unresolved bias concerns can mandate a new trial—offering both a cautionary note and a safeguard for defense counsel.