Royce Gouveia v. Nolan Espinda, 926 F.3d 1102

Royce Gouveia was tried in Hawaii for manslaughter; after evidence and closing arguments the jury retired and sent a note saying it had reached a verdict, then a second note expressing safety concerns about a menacing man seen on the prosecution side of the courtroom.
The court individually questioned jurors; all twelve said the man did not affect their individual votes, though some reported fear and one suggested others may have been impacted.
The prosecution moved for a mistrial; the court granted the mistrial over Gouveia’s objection, finding "manifest necessity" because the verdict was allegedly tainted; the verdict form (later unsealed) showed a unanimous not-guilty vote.
Hawaii appellate courts affirmed the mistrial as supported by the trial court’s finding that the presumption of prejudice could not be overcome beyond a reasonable doubt.
Gouveia filed a federal habeas petition under 28 U.S.C. § 2241; the district court granted relief, concluding there was no manifest necessity and retrial would violate double jeopardy.
The Ninth Circuit affirmed: §2241 petitions are not barred by Rooker–Feldman, and the mistrial lacked manifest necessity so retrial would violate the Double Jeopardy Clause.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker–Feldman bars a §2241 habeas petition challenging a state-court mistrial	Gouveia: Rooker–Feldman does not apply to habeas under §2241; habeas is a separate statutory grant	State: Rooker–Feldman prevents district-court review of state-court decisions and thus bars §2241 here	Held: Rooker–Feldman inapplicable; §2241 confers jurisdiction for pretrial double-jeopardy habeas claims
Whether the trial court had "manifest necessity" to declare a mistrial (Double Jeopardy)	Gouveia: Jurors uniformly said their votes were unaffected; alternatives to mistrial existed; verdict not final — retrial would violate double jeopardy	State: Safety concerns of jurors and potential juror taint justified mistrial; trial court properly exercised discretion	Held: No manifest necessity. Trial court failed to adequately consider less drastic alternatives and gave insufficient reason to discard the jury’s (nonfinal) verdict; retrial would violate Double Jeopardy

Rooker v. Fid. Tr. Co., 263 U.S. 413 (statutory bar on district-court appellate review of state-court final judgments)
D.C. Ct. App. v. Feldman, 460 U.S. 462 (same)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker–Feldman as statutory doctrine and habeas exception)
Gruntz v. County of Los Angeles (In re Gruntz), 202 F.3d 1074 (9th Cir. en banc) (habeas not precluded by Rooker–Feldman)
Stow v. Murashige, 389 F.3d 880 (9th Cir.) (§2241 proper vehicle for pretrial double-jeopardy challenges)
Arizona v. Washington, 434 U.S. 497 (manifest necessity standard and deference framework)
United States v. Perez, 22 U.S. (9 Wheat.) 579 (origin of "manifest necessity" rule)
United States v. Jorn, 400 U.S. 470 (balancing defendant's valued right against public interest)
Blueford v. Arkansas, 566 U.S. 599 (preliminary jury indications lack finality for acquittal purposes)