Blake v. State, 304 Ga. 747

In March 2015, Amountrae Hawkins was shot and killed during a drug transaction; R'Shon Blake was indicted on multiple counts including malice murder and felony murder.
Jury trial began June 19, 2017; deliberations occurred June 22–23 and resumed after the weekend.
After the weekend, the foreperson reported that Juror 17 had done outside research (including consulting a police detective per the foreperson) and shared legally incorrect examples and sentencing information with other jurors.
The trial judge questioned the foreperson and Juror 17 on the record; Juror 17 admitted to Internet research and said other jurors also researched and shared information.
The judge considered alternatives (removal/replacement, recharging, further inquiry) but declared a mistrial over Blake’s objection; Blake filed a plea in bar asserting double jeopardy.
The Georgia Supreme Court reviewed whether the mistrial was supported by the “manifest necessity” standard and affirmed denial of the plea in bar.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether retrial was barred by double jeopardy because the court declared a mistrial over Blake's objection without manifest necessity	Blake: Mistrial was not supported by manifest necessity; retrial is barred	State: Jury exposure to outside legal information compromised fairness; mistrial necessary and retrial permitted	Court: No abuse of discretion; high degree of necessity existed and retrial not barred
Whether juror misconduct (independent legal research/shared misinformation) required dismissal rather than cure	Blake: Alternatives (remove juror, recharge, further questioning) could have preserved trial	State: Alternatives inadequate given extent of contamination; issue would be a major appellate problem	Court: Trial judge reasonably considered and rejected alternatives; mistrial appropriate
Whether the record shows the trial court actually exercised discretion in declaring mistrial	Blake: Record insufficient to demonstrate considered exercise of discretion	State: Judge conducted on-the-record questioning and considered circumstances	Court: Record demonstrates deliberate exercise of discretion and deference due to trial judge

Harvey v. State, 296 Ga. 823 (manifest necessity standard requires high degree of necessity)
Laguerre v. State, 301 Ga. 122 (weigh defendant's right to conclude trial against public interest in fair trials)
Tubbs v. State, 276 Ga. 751 (trial judge’s discretion and deference where reasonable judges could differ)
Meadows v. State, 303 Ga. 507 (broad discretion where mistrial based on outside influences; great deference on appeal)
Arizona v. Washington, 434 U.S. 497 (U.S. Supreme Court standard on mistrial and double jeopardy)
Chambers v. State, 321 Ga. App. 512 (reversal where juror’s Internet research and misinformation influenced deliberations)