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State v. Baker - 453 Md. 32, 160 A.3d 559 (2017)

Rule:

There exists manifest necessity for a mistrial only if: (1) there was a high degree of necessity for the mistrial; (2) the trial court engaged in the process of exploring reasonable alternatives to a mistrial and determined that none was available; and (3) no reasonable alternative to a mistrial was, in fact, available. Reviewing courts have an obligation to satisfy themselves that the trial judge exercised sound discretion in declaring a mistrial. However, the absence of an explicit finding of manifest necessity does not render the trial court's ruling constitutionally defective. Instead, the reviewing court must be persuaded by the record that the trial judge acted responsibly and deliberately, and accorded careful consideration to the defendant's interest in having the trial concluded in a single proceeding. 

Facts:

Darrell Ellis filed criminal charges against the Respondent, Andrew Daniel Baker, for an incident that occurred on January 13, 2015, where neighbors reported shots being fired both into and from within a residence in Elkton, Maryland ("the First Incident"). In exchange, Mr. Baker filed criminal charges against Mr. Ellis for an alleged assault that occurred on January 15, 2015 ("the Second Incident"). At Mr. Baker's trial for allegedly assaulting Mr. Ellis and his girlfriend, Kimberly Mitchell, during the First Incident, it was revealed that Mr. Ellis' defense counsel for the charges related to the Second Incident was the brother of the assistant state's attorney who was prosecuting Mr. Baker for the charges stemming from the First Incident. When the trial court learned this information, it declared a mistrial over Mr. Baker's objection. Mr. Baker subsequently filed a motion to dismiss his indictments on grounds of double jeopardy, which was denied. Mr. Baker noted an interlocutory appeal to the Court of Special Appeals, which reversed the decision of the lower court and ordered the indictments be dismissed. The State then petitioned a writ of certiorari, requesting  review on whether the mistrial was supported by manifest necessity.

Issue:

Where a trial court sua sponte declared a mistrial over an objection that was not supported by manifest necessity, did the mistrial amount to an abuse of discretion and was retrial barred by double jeopardy principles?

Answer:

Yes

Conclusion:

The Court of Appeals of Maryland held that the trial court's sua sponte declaration of a mistrial over Mr. Baker's objection was not supported by manifest necessity. It was unclear whether there was a reasonable alternative to the mistrial available that could have alleviated the conflict caused by offering a witness immunity in exchange for his testimony, and the circuit court and the State failed to include sufficient consideration of adequate alternatives on the record. The Court reiterated that any doubt must be resolved in favor of defendant. Thus, the mistrial amounted to an abuse of discretion. Therefore, the Court ruled that the retrial of Mr. Baker was barred by double jeopardy principles and that the circuit court erred in denying Mr. Baker's motion to dismiss the indictments. The Court affirmed the judgment of the Court of Special Appeals.

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