The Court determined that (1) a district court's failure to instruct the jury to restart deliberations when an alternate juror replaces an original juror is an error of constitutional dimension; (2) unpreserved errors are reviewed for plain error regardless of whether they are of constitutional dimension; (3) A prejudicial error can result if most of the jury’s deliberation time takes place before the error related to the replacement of an original juror occurs.
Kahn, Gil, "Summary of Martinorellan v. State, 131 Nev. Adv. Op. 6" (2015). Nevada Supreme Court Summaries. 851.