Gouveia v. Espinda, No. 17-16892 (9th Cir. 2019)
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The Ninth Circuit affirmed the district court's judgment granting petitioner habeas corpus relief under 28 U.S.C. 2241, based on his challenge to the trial court's grant of a mistrial. In this case, after the jury reached a verdict but before the verdict was announced, the jurors expressed concern for their safety because of a scary-looking man in the courtroom.
The panel held that the district court correctly held that the Rooker-Feldman doctrine was inapplicable in section 2241 petitions. On the merits, the panel held that the district court did not err in concluding that retrying defendant would violate the Double Jeopardy Clause, because the trial court erred in concluding that there was manifest necessity for a mistrial. Even under a more deferential standard, the trial court's manifest necessity determination was erroneous because the trial court failed to provide any meaningful consideration of alternatives to mistrial.
Court Description: Habeas Corpus. The panel affirmed the district court’s judgment granting Royce Gouveia’s 28 U.S.C. § 2241 habeas corpus petition challenging the trial court’s grant of a mistrial in his Hawaii manslaughter case in which, after the jury reached a verdict but before the verdict was announced, jurors expressed concern for their safety because of a scary-looking man in the courtroom. The panel held that the Rooker-Feldman doctrine does not preclude a federal district court from exercising jurisdiction under § 2241. The panel did not need to determine precisely what level of deference is owed to the trial court’s determination that there was manifest necessity for a mistrial. The panel held that even under a more deferential standard, the trial court’s manifest-necessity determination was erroneous because the trial court failed to provide any meaningful consideration of alternatives to mistrial. The panel concluded that the district court therefore did not err in concluding that retrying Gouveia would violate the Double Jeopardy Clause.
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