Since Ricks we have explained that "the primary objective of the JCR — to ensure that each county master jury list is ‘no less than 85% inclusive’ of the county's adult population — is a prophylactic measure that is not tied to any specific constitutional or statutory mandate." Sinkfield v. State , 311 Ga. 524, 529 (1), 858 S.E.2d 703 (2021). When a violation of the JCR is shown before trial, a defendant may be able to obtain pretrial relief requiring the JCR to be followed in his trial regardless of any showing of harm.
Structural errors are not subject to harmless error review; they are cause for "automatic" reversal. Sinkfield v. State , 311 Ga. 524, 527-528 (1), 858 S.E.2d 703 (2021) ; see also Alexander v. State , 313 Ga. 521, 526 (2), 870 S.E.2d 729 (2022). But we need not decide whether the trial court's handling of matters related to Armour's brother constituted a structural error.