Ricketts v. Adamson

Adamson (defendant) was charged with first-degree murder for the car bombing of Donald Bolles. He pleaded guilty to second-degree murder in exchange for agreeing to testify against Max Dunlap and James Robinson, with the agreement warning that his original first-degree murder charge would be reinstated if he refused to testify or lied. Adamson testified, Dunlap and Robinson were convicted, and Adamson was sentenced under the deal. After their convictions were later reversed, prosecutors asked Adamson to testify again at the retrial; he refused, believing his obligation ended at sentencing, and ultimately pled the Fifth. Prosecutors then refiled the original first-degree murder charge. Adamson's double-jeopardy challenge to the new charge was denied, and though he later offered to testify, the state refused the offer. He was convicted of first-degree murder and sentenced to death; the Ninth Circuit granted habeas relief on double-jeopardy grounds.