| Blueford v. Arkansas | |
|---|---|
 | |
| Argued February 22, 2012 Decided May 24, 2012 | |
| Full case name | Alex Blueford v. State of Arkansas |
| Docket no. | 10-1320 |
| Citations | 566 U.S. 599 (more) 132 S. Ct. 2044; 182 L. Ed. 2d 937 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Motion to dismiss denied, No. CR2008-2797, Pulaski County Circuit Court, Fourth Division; affirmed, 2011 Ark. 8, 370 S.W.3d 496, 2011 Ark. LEXIS 7 (Ark. 2011); rehearing denied, 2011 Ark. LEXIS 365 (Ark. 2011); appeal granted sub nom. Blueford v. Arkansas, 132 S. Ct. 397, 181 L. Ed. 2d 255, 2011 U.S. LEXIS 7339 (2011) |
| Holding | |
| The Double Jeopardy Clause does not bar a retrial on certain counts after the jury told the trial court it had voted unanimously against those charges but was deadlocked and unable to reach a verdict on other counts, causing the court to declare a mistrial. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Roberts, joined by Scalia, Kennedy, Thomas, Breyer, Alito |
| Dissent | Sotomayor, joined by Ginsburg, Kagan |
| Laws applied | |
| U.S. Const. amend. V (Double Jeopardy Clause) | |
Blueford v. Arkansas, 566 U.S. 599 (2012), was a decision of the Supreme Court of the United States that clarified the limits of the Double Jeopardy Clause. The Supreme Court held that the Double Jeopardy Clause does not bar retrial of counts that a jury had previously unanimously voted to acquit on, when a mistrial is declared after the jury deadlocked on a lesser included offense.
Alex Blueford was tried on capital murder and three lesser included offenses: first-degree murder, manslaughter, and negligent homicide. After deliberating, the jury reported that it had unanimously voted to acquit on the charges of capital murder and first-degree murder, but had deadlocked on manslaughter and had not voted on negligent homicide. The trial court declared a mistrial and denied a motion to dismiss the charges of capital murder and first-degree murder on double jeopardy grounds. The Supreme Court of Arkansas affirmed the denial of the motion on interlocutory appeal.
The Supreme Court affirmed the decision of the Supreme Court of Arkansas. Writing for the majority, Chief Justice Roberts held that because the jury did not formally acquit on any charges, the report of the foreperson that the jury had unanimously voted against capital murder and first-degree murder "lacked the finality" required to prevent a retrial. Further, Chief Justice Roberts found that the trial court's declaration of a mistrial was proper under the circumstances. Dissenting, Justice Sotomayor wrote that the state should not be able to retry Blueford on capital and first-degree murder because the jury had announced its unanimous vote against capital and first-degree murder in open court.