People v. CarbajalAnnotate this Case
Defendant was charged with sexually molesting two victims. A jury convicted Defendant of some counts involving one victim but deadlocked on all counts involving the other victim. Nevertheless, the jury returned a true finding on an allegation that Defendant had committed offenses against multiple victims. Believing the jury's true finding was in error, the trial court ordered further deliberations. The jury eventually returned with a blank verdict form and indicated it had deadlocked on the multiple victim allegation. A mistrial was declared, and Defendant was retried. A second jury convicted Defendant of counts involving the other victim and found true the multiple victim allegation. The court reversed the second jury's true finding on the multiple victim allegation, concluding that double jeopardy principles barred Defendant's retrial on the multiple victim allegation. The Supreme Court reversed, holding that because the first jury had no authority to decide or even to consider the multiple victim allegation after it deadlocked on the counts involving the other victim, no valid verdict could have been rendered on that allegation, and thus double jeopardy did not bar retrial on that allegation.