Although cautioning against the precipitous resort to an Allen charge by trial courts, the U.S. Court of Appeals for the Second Circuit has nonetheless upheld such a charge given by a judge after only one hour of jury deliberations.

The circuit on Tuesday said that Eastern District Judge I. Leo Glasser's instructions that the jury continue working in a sex-with-a-minor case were not unduly coercive despite the fact that such charges are usually given only after extensive deliberations have resulted in deadlock.