Arizona v. Washington
United States Supreme Court
434 U.S. 497 (1978)
Relevant factsFree
The defendant's second-trial defense counsel referenced evidence supposedly hidden from him at the first trial, prompting the prosecution to move for a mistrial fearing irremediable juror prejudice; the judge granted the mistrial without expressly finding "manifest necessity" or explaining why a cautionary jury instruction would have been inadequate, and a habeas court later found the Double Jeopardy Clause barred a third trial.
IssueFree
Whether "manifest necessity" for granting a mistrial means that different standards are appropriate for mistrials granted for different reasons.