Simmons v. State, 57 A.3d 541

Appellant Stephen Simmons was charged with first‑degree murder in Prince George’s County.
During opening, defense disclosed Simmons offered to take a lie detector test; court sustained the State’s objection and gave a curative instruction.
Two days later, after the State’s witnesses testified, the State moved for a mistrial based on the lie detector remark; the court granted the mistrial.
Simmons moved to dismiss the charges on double jeopardy grounds; the circuit court denied the motion.
The State argued the remark impermissibly prejudiced the jury and created a need for a new trial; the circuit court found manifest necessity.
On appeal, Simmons contends there was no manifest necessity for the mistrial; the court affirms the circuit court’s ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether manifest necessity supported a mistrial	Simmons; no manifest necessity	Simmons; immediate mistrial unnecessary	Manifest necessity existed; mistrial upheld
Whether defense opening remark about a lie detector prejudiced the State's case	State; prejudicial impermissible comment requiring mistrial	Simmons; isolated remark, not dispositive	Remark highly prejudicial; supports mistrial
Whether double jeopardy bars retrial after a mistrial for manifest necessity	State; retrial permissible with manifest necessity	Simmons; double jeopardy prohibits retrial absent manifest necessity	Retrial permissible; double jeopardy not violated

Washington v. State, 434 Md. 498 (Md. 1978) (improper opening statements may justify mistrial when prejudicial)
Kosmas v. State, 316 Md. 587 (Md. 1989) (polygraph references are highly prejudicial; multiple factors assess prejudice)
State v. Hawkins, 326 Md. 270 (Md. 1992) (polygraph references generally inadmissible; juries should not hear them)
Pantazes v. State, 141 Md.App. 422 (Md. 2001) (polygraph references disfavored; reflects longstanding rule)
Taylor v. State, 381 Md. 602 (Md. 2004) (double jeopardy and manifest necessity framework applied)