This method may be used in many U.S. states. In some states it may be used for both criminal and civil cases, in other states for only one of the two kinds. In at least the state of Washington, it is the default method of choosing a jury. Some courts of appeals in the U.S. have determined that a struck jury offers greater opportunity to shape the final jury than the more common "sequential" (also known as "strike and replace" or "jury box") method, where peremptory challenges can only be issued against those jurors already seated, with no knowledge of the replacement.