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Bolandian Insider Trading Conviction Vacated, Remanded

The Ninth Circuit vacated Shahriyar Bolandian's insider trading conviction and remanded for a new trial, holding that the district court plainly erred by failing to independently investigate a juror (Juror No. 6) who expressed uncertainty about his impartiality. The panel held that defense counsel cannot waive a district court's independent duty to conduct a reasonable inquiry into juror bias that emerges during trial; without such an inquiry, Bolandian forfeited — rather than waived — his bias challenge, triggering plain-error review on appeal.