396, 38 L.Ed.2d 368 (1973)). Since Brennan failed to object to the supplemental charge we review only for plain error. See United States v. Eastern Medical Billing, Inc., 230 F.3d 600, 610 (3d Cir.2000). The leading case addressing allegations of a coercive supplemental jury charge is well known. In Allen v. United States, 164 U.S. 492, 17 S.Ct. 154, 41 L.Ed. 528 (1896), the Supreme Court upheld a supplemental jury charge which recommended that the jurors with views in the minority consider whether their views might be erroneous. Nonetheless, in 1969, this Circuit developed a prophylactic rule prohibiting the use of such an Allen charge because of its power to coerce. See United States v. Fioravanti, 412 F.2d 407 (3d Cir.1969); see also Eastern Medical Billing, Inc., 230 F.3d at 613-15 (<HOLDING>). We suggested, however, that a charge would
holding that an allen charge was not inherently coercive even though jury was split 111 because the judge did not know the identity of the holdout juror holding second modified allen charge coercive per se unless jury requests it holding that allen charge given by court was coercive and required a new trial holding when giving an allen charge the trial court must avoid coercive deadlines holding that trial courts jury charge did not amount to reversible error given that plaintiff failed to show she was prejudiced by inapplicable portion of trial courts charge