A challenge is an objection made to the trial jurors that may be taken by any party to the action, and is of the following classes and types:
§ 225.Challenges
Title 3. Persons Specially Invested With Powers of a Judicial Nature · Chapter 1. Trial Jury Selection and Management Act · Enacted 1988 · no amendments on record · Last verified July 28, 2026
In one sentenceSection 225 defines a challenge as an objection to trial jurors that any party may raise, splits challenges into a written challenge to the whole panel and challenges to an individual juror, and further divides individual-juror challenges into for-cause challenges (general disqualification, implied bias, or actual bias) and peremptory challenges.
Full Text of § 225
(a) A challenge to the trial jury panel for cause.
(1) A challenge to the panel may only be taken before a trial jury is sworn. The challenge shall be reduced to writing, and shall plainly and distinctly state the facts constituting the ground of challenge.
(2) Reasonable notice of the challenge to the jury panel shall be given to all parties and to the jury commissioner, by service of a copy thereof.
(3) The jury commissioner shall be permitted the services of legal counsel in connection with challenges to the jury panel.
(b) A challenge to a prospective juror by either:
(1) A challenge for cause, for one of the following reasons:
(A) General disqualification—that the juror is disqualified from serving in the action on trial.
(B) Implied bias—as, when the existence of the facts as ascertained, in judgment of law disqualifies the juror.
(C) Actual bias—the existence of a state of mind on the part of the juror in reference to the case, or to any of the parties, which will prevent the juror from acting with entire impartiality, and without prejudice to the substantial rights of any party.
(2) A peremptory challenge to a prospective juror.
Plain-English Summary
Section 225 is the framework section for jury challenges: a challenge is an objection made to the trial jurors, and any party to the action may raise one. The section sorts challenges into classes and types.
A challenge to the panel as a whole must be made in writing before the jury is sworn, plainly and distinctly stating the facts behind it, with reasonable notice given to the other parties and to the jury commissioner, who may retain counsel to respond.
A challenge to an individual juror comes in two forms. A challenge for cause rests on one of three grounds: general disqualification, meaning the juror is disqualified from serving in this particular action; implied bias, where facts, once established, disqualify the juror as a matter of law; or actual bias, meaning a state of mind toward the case or a party that would prevent the juror from acting with entire impartiality and without prejudice to a party’s substantial rights. The second form is a peremptory challenge, which does not require a stated ground under § 226.
Frequently Asked Questions
What is a “challenge” in California jury selection?
Section 225 defines it as an objection made to the trial jurors, which any party to the action may raise.
What is the difference between a challenge to the panel and a challenge to an individual juror?
A panel challenge attacks the whole panel and must be written, filed before the jury is sworn, and served on the other parties and the jury commissioner; an individual-juror challenge targets one prospective juror and can be for cause or peremptory.
What are the three grounds for a for-cause challenge?
General disqualification, implied bias, and actual bias, each defined in § 225(b)(1).
What is the difference between implied bias and actual bias?
Implied bias exists when established facts disqualify the juror as a matter of law, while actual bias is a genuine state of mind toward the case or a party that would prevent impartial service.
Does a peremptory challenge require a stated reason?
Amendment History
Added Stats 1988 ch 1245 § 2.
Source & verification. Section text is reproduced verbatim from
the Deering's California Codes Annotated / vLex. Enacted by the California Legislature.
Last verified July 28, 2026.
· Official source
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