Sunday, November 3, 2013

United States v. Sanford case brief

United States v. Sanford case brief summary
429 U.S. 14 (1976)

CASE SYNOPSIS
The government sought a writ of certiorari to review an order of the United States Court of Appeals for the Ninth Circuit dismissing on double jeopardy grounds the government's appeal of an order dismissing an indictment for illegal game hunting.

CASE FACTS
Defendants were indicted for illegal game hunting in Yellowstone National Park. A jury trial resulted in a hung jury, and the district court declared a mistrial. The district court subsequently granted defendants' motion to dismiss the indictment. The court of appeals dismissed the government's appeal, holding that retrial was barred by the double jeopardy clause of U.S. Constitutional Amendment V. The government petitioned for certiorari.

DISCUSSION
  • The United States Supreme Court vacated the judgment and remanded for further consideration in light of the Court's intervening decision. 
  • The court of appeals adhered to its prior determination on remand. 
  • The government sought certiorari from that ruling. 
  • The Court reversed and remanded for further proceedings, holding that the government was not precluded on double jeopardy grounds from retrying defendants where the first trial ended in a mistrial of manifest necessity because of the hung jury.

CONCLUSION
The Court granted the petition for certiorari, reversed the judgment of the court of appeals, and remanded for further proceedings, holding that the government was not precluded on double jeopardy grounds from retrying defendants where the first trial ended in a mistrial of manifest necessity because of a hung jury.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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