Barry Bonds avoided conviction on three of the four counts against him, but legal analysts say he will have trouble getting the lone guilty verdict thrown out.
On Wednesday, a jury convicted Bonds of obstruction of justice but deadlocked on whether he committed perjury in testifying before a grand jury about performance-enhancing drugs more than seven years ago.
U.S. District Judge Susan Illston presided over the trial and she is rarely overturned on appeal. Observers say she deftly handled the three-week trial.
Bonds is due back in court May 20 for another hearing.