Coggins v. Commonwealth
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The Supreme Judicial Court affirmed the judgment of the single justice of the Court denying Appellant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that principles of double jeopardy did not bar Appellant's retrial, and therefore, the single justice neither erred nor abused its discretion in denying relief.
Appellant was indicted for murder in the first degree and arson in a dwelling. After the jury deadlocked, Appellant's jury trial ended in a mistrial. Appellant subsequently moved to dismiss the indictments, arguing that the Commonwealth failed to present sufficient evidence at his first trial to warrant a conviction with respect to either charge, and therefore, principles of double jeopardy barred his retrial. The Supreme Judicial Court affirmed, holding that the evidence was sufficient for a rational jury to convict Appellant of murder in the first degree, as well as arson in a dwelling.
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