Mansfield v. State
29 A.3d 569
Md.2011Background
- Mansfield was tried in a bench trial in Caroline County on five counts of sexual offenses involving a minor, arising from alleged 2005 conduct.
- Before jeopardy attached, the judge knew Mansfield had two prior sexual-conviction cases involving minors; one prior case was presided over by her, another by a different judge.
- The State anticipated the victim would testify about a delayed report; defense indicated Mansfield would testify that the alleged acts did not happen.
- The State presented the victim, her mother, a former friend, and three others; no forensic evidence was introduced.
- The trial judge, sua sponte and over Mansfield’s objection, declared a mistrial after evidence concluded, citing her pretrial knowledge of Mansfield’s prior convictions and a credibility impasse.
- Mansfield moved to dismiss on double jeopardy grounds; the circuit court denied, and the Court of Special Appeals affirmed that ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether manifest necessity excused double jeopardy here | Mansfield argues lack of manifest necessity; judge could have recused instead. | State contends mistrial necessary to preserve fairness given credibility conflict. | No manifest necessity; retrial barred |
| Whether pre-jeopardy knowledge of prior convictions tainted judge's impartiality | Judge’s pretrial knowledge compromised impartiality and undermined the trial. | Impartiality intact; mistrial justified by inability to assess credibility fairly. | Impartiality impaired; recusal available; mistrial improper |
| Whether the appropriate remedy was recusal rather than mistrial | Recusal before jeopardy attached was a feasible alternative to a mistrial. | Recusal not adequately explored; mistrial necessary for fairness. | Recusal available; mistrial inappropriate |
| Effect of the mistrial on Mansfield's double jeopardy rights | Because of pretrial knowledge, retrial violates double jeopardy. | Mistrial permitted under manifest necessity. | Retrial barred; double jeopardy applies |
Key Cases Cited
- United States v. Perez, 22 U.S. (9 Wheat.) 579 (1824) (manifest necessity standard for mistrial)
- Cornish v. State, 272 Md. 312, 322 A.2d 880 (1974) (mistrial decisions in bench trials; manifest necessity standard)
- Illinois v. Somerville, 410 U.S. 458 (1973) (scope of double jeopardy and mistrial standards)
- United States v. Jorn, 400 U.S. 470 (1971) (prejudice and mistrial considerations in retrial)
- Arizona v. Washington, 434 U.S. 497 (1978) (right to one opportunity for trial; dangers of retrial)
- Sartori, 730 F.2d 973 (4th Cir. 1984) (recusal as alternative to mistrial; appearance of impartiality)
- In re Kevin, 402 Md. 624 (2008) (jeopardy attaches when evidence begins; bench trial standard)
- Hubbard v. State, 395 Md. 73 (2006) (limits on retrial after mistrial; high degree of necessity)
- Cornish v. State, 272 Md. 312 (1974) (summary of Perez framework and manifest necessity principles)