State v. Hart
Annotate this CaseDefendant was indicted on several drug-related counts, which resulted in a two-day jury trial. During jury deliberations, the trial court received a jury note stating that the jury was deadlocked on a particular count (Count 1). Arrangements were made to bring Defendant to the courtroom, but Defendant had been transported to a hospital due to a medical emergency. The court summoned the jury foreperson to discuss the deadlock, and in Defendant’s absence, the judge accepted a partial verdict from the jury. Defendant was found guilty on three counts, and the trial court declared a mistrial on Count 1 on the ground of “manifest necessity.” The trial court subsequently ordered a new trial, concluding that it erred in receiving the partial verdict in Defendant’s absence. The judge, however, denied defense counsel’s motion to dismiss Count 1. The Court of Special Appeals reversed as to Count 1, concluding that, due to Defendant’s involuntary absence, manifest necessity did not exist to declare a mistrial as to Count 1, and therefore, retrial was barred by double jeopardy principles. The Court of Appeals affirmed, holding (1) the trial judge erred in declaring a mistrial in Defendant’s involuntary absence without first continuing the case; and (2) double jeopardy barred a retrial of Count 1.
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