User blog comment:SimBrotherCo/Was It Fair to Not Let Corinne on the Jury?/@comment-1827503-20130411134459

It's not exactly legal to change the number of jurors based off who just got voted out. So if Penner was blindsided at final 12 last season, he wouldn't have been a juror either.

And if you want to be technical, Joe made the merge and missed the jury in Tocantins, though he was evacuated so it doesn't really count.