Dismissed juror in Corrine Brown case was holding out for acquittal

When is it appropriate to dismiss a "holdout" juror? Representative Corrine Brown, who was convicted late last week, will argue that the judge should not have dismissed a juror holding out for innocence:

A juror dismissed from former U.S. Rep. Corrine Brown’s fraud trial told other jurors “the Holy Spirit” said Brown was innocent as the jury deliberated, according to a transcript the trial judge unsealed after a hearing Monday.
U.S. District Judge Timothy Corrigan’s decision to remove that juror will evidently become part of Brown’s effort to challenge her conviction last week on 18 out of 22 fraud and tax charges that could lead to years of imprisonment.
Although he hadn’t requested one Monday, Brown’s attorney, James W. Smith III, told reporters last week he planned to seek a new trial.
Corrigan acknowledged disagreement over the juror’s dismissal during a hearing that touched on a range of subjects involving the now-discharged jury.
“It is obviously a matter of contention in this case as to whether the court acted correctly,” Corrigan said.
“I thought it was the right decision, but I know you have rights and I want you to be able to take advantage of those,” the judge told Smith before denying a pair of oral motions that would have raised the possibility of attorneys talking with some jurors about their verdict.