Vaughn v. State
Annotate this CaseThis case involved a trial court's discretion in granting a mistrial. Defendant vacillated throughout the trial seeking to proceed pro se and at other times wanting court-appointed counsel. Ultimately, the relationship between Defendant and his counsel reached its low point when later in the trial Defendant testified. Defendant complained to the jury about his counsel's trial strategy, and his response to counsel risked a mistrial. The judge then instructed Defendant to stop speaking and directed the jury to be removed from the courtroom. Before the jury left the courtroom, the judge directed the bailiff to cover Defendant's mouth so he would stop talking. Defendant later completed his direct and cross-examinations without incident. Only after Defendant completed his testimony did defense counsel move for a mistrial. The trial court refused to grant a mistrial. The Supreme Court affirmed, holding that Defendant did not suffer actual harm from the bailiff restraining him, and therefore, the court did not abuse its discretion in denying the motion for mistrial.
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