Blake v. State, 304 Ga. 747

R’Shon Blake was indicted for malice murder, felony murder counts, armed robbery, aggravated assault, and related firearm offenses after a 2015 killing; jury trial began June 2017.
During deliberations, the jury foreperson reported that Juror 17 had done outside research and discussed legal definitions and sentencing with other jurors.
Juror 17 admitted on the record to Internet research about the legal differences between malice murder and felony murder and to sharing those findings; she also claimed other jurors had done outside research and shared it.
The trial judge questioned the foreperson and Juror 17, considered alternatives (remove juror, recharge jury, further inquiry), and concluded the jury had been exposed to improper outside information.
Over Blake’s objection, the trial court declared a mistrial; Blake filed a plea in bar arguing double jeopardy barred retrial because the mistrial lacked manifest necessity.
The trial court denied the plea in bar; the Georgia Supreme Court affirmed, holding the mistrial was within the trial court’s discretion given the jury’s exposure to outside legal information.

Issue	Blake's Argument	State's Argument	Held
Whether retrial is barred by double jeopardy after a mistrial declared over defendant's objection	Mistrial lacked "manifest necessity" because less drastic cures (removal of juror, recharging, further inquiry) were available	Trial judge properly exercised broad discretion; jury exposure to outside legal information justified mistrial	Court held mistrial was manifestly necessary; retrial not barred
Whether juror misconduct (independent legal research) required reversal rather than mistrial	Juror misconduct did not justify mistrial absent manifest necessity	Jury-wide improper research and sharing threatened fairness; mistrial appropriate	Court found exposure to outside information compromised verdict integrity; mistrial proper
Sufficiency of the trial court’s inquiry before declaring mistrial	Court failed to fully explore less drastic alternatives or question all jurors	Judge questioned foreperson and implicated juror, considered alternatives, reasonably concluded mistrial necessary	Court concluded record shows discretion was exercised and alternatives reasonably rejected
Standard of review for mistrial based on outside influences	N/A (challenge to trial court’s exercise of discretion)	Great deference to trial court where outside influences implicated	Court applied manifest necessity standard and deferred to trial court’s judgment

Harvey v. State, 296 Ga. 823 (sets out manifest necessity standard and requirement that record show exercise of discretion)
Laguerre v. State, 301 Ga. 122 (discusses high degree of necessity and weighing defendant’s rights against public interest)
Tubbs v. State, 276 Ga. 751 (trial-court discretion on mistrial; reasonable judges may differ)
Meadows v. State, 303 Ga. 507 (great deference where mistrial based on outside influences and no prosecutorial misconduct)
Arizona v. Washington, 434 U.S. 497 (federal guidance on manifest necessity and mistrials)
Owens v. State, 251 Ga. 313 (juror exposure to unauthorized outside influence threatens trial integrity)
Chambers v. State, 321 Ga. App. 512 (juror Internet research about legal terms and misinformation required reversal)
Steele v. State, 216 Ga. App. 276 (juror looked up legal/sentencing info and jury relied on it; new trial required)
Moore v. State, 172 Ga. App. 844 (juror legal research on murder charges and discussion with jury warranted reversal)
Hodges v. State, 302 Ga. 564 (harmless where juror looked up words but did not share with jury)
O’Donnell v. Smith, 294 Ga. 307 (no showing of effect on verdict when juror did outside research and did not communicate findings)
Varner v. State, 285 Ga. 334 (affirmed mistrial where jurors were inadvertently provided inadmissible evidence)
Watkins v. State, 237 Ga. 678 (jurors’ unauthorized fact-finding and reporting to jury required reversal)