What Is NOT a Reason Cited by the Supreme Court

What is NOT a reason cited by the Supreme Court for why size is related to a jury's function?

A) Jury size must be large enough to allow for better recall of testimony.
B) Jury size must be large enough to promote group deliberation.
C) Jury size must be large enough to be free from outside intimidation.
D) Jury size must be large enough to obtain a fair cross-section of the community.