People v. ArandaAnnotate this Case
The Supreme Court held that the rule set forth in Stone v. Superior Court, 31 Cal.3d 503, that a court must accept a partial verdict of acquittal as to a charged greater offense when a jury has expressly indicated that it has acquitted on that offense but has deadlocked on uncharged lesser included offenses, has not been abrogated by the United States Supreme Court's decision in Blueford v. Arkansas, 566 U.S. 599, which concluded that federal double jeopardy principles do not require a court to accept a partial verdict.
Defendant was charged with murder. At the close of evidence, the court instructed the jury on first degree murder and uncharged lesser included offenses. The jury foreperson reported that jurors were split between second degree murder, voluntary manslaughter, and a not guilty verdict. The court concluded that the jury was deadlocked and declared a mistrial. Defendant moved to dismiss the first degree murder allegation on double jeopardy grounds, arguing that the court's failure to receive a partial acquittal verdict on first degree murder barred a retrial on that charge. The court dismissed the first degree murder charge. The court of appeal affirmed. The Supreme Court affirmed, holding (1) Stone survives Blueford under California law; and (2) the trial court improperly declared a mistrial as to first degree murder.