Mansfield v. State
Annotate this CasePetitioner Christopher Mansfield was tried in a bench trial at the circuit court on five counts charging statutory sex-related offenses. At the close of the evidence, the trial judge, sua sponte and over Petitioner's objection, declared a mistrial, explaining that her knowledge of Petitioner's prior convictions and the partiality it engendered made a mistrial manifestly necessary. Petitioner moved to dismiss the indictment on double jeopardy grounds, arguing that there was not manifest necessity for the granting of the mistrial where the trial judge had knowing of Petitioner's prior convictions well before the trial began. The motions judge and the court of special appeals upheld the decision. The Court of Appeals reversed, holding that under these circumstances, when it is the court that is the trier of facts, and the court's impartiality, whether due to a personal bias or prejudice toward a criminal defendant or an inability to resolve disputed factual allegations, is impaired, manifest necessity does not exist when the reasonable alternative of recusal existed prior to jeopardy attaching. Remanded.
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