Based on… what?
Juror misconduct? Cuz that seems about all it could be.
Juan Merchan has overwhelmingly demonstrated that anything can be anything he wants it to be.
Here are the rules for removal of a juror. Notice that failure to deliberate leaves a lot of wiggle room: https://legal-info.lawyers.com/criminal/criminal-law-basics/excluding-jurors-removing-and-disqualifying.html
Another thing is if the prosecution would try to contact the hold-out, and then the judge could remove that juror.
There are a lot of dirty tricks that could be played.
Jurors can also be dismissed if they have a family emergency or are ill - both of which can be managed by the “six ways from Sunday at getting back at you” Deep State...