348 P.3d 910
Ariz. Ct. App.2015Background
- Woods was convicted after a jury trial of multiple counts of aggravated assault, kidnapping, and armed/aggravated robbery, with total sentence 78.5 years.
- The first trial ended in a hung jury, yielding a mistrial and a new trial was ordered.
- During the second trial, L.C. disrupted proceedings with profanity and hostility toward Woods; the court denied a mistrial initially.
- External commotion outside the courtroom and police activity potential observed by jurors led the state to move for a mistrial, which the court granted without prejudice.
- Woods appealed arguing double jeopardy and improper in-court identification; the court reversed and remanded to dismiss with prejudice.
- The dissent would have upheld the mistrial, arguing manifest necessity and deference to trial court discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the mistrial violated double jeopardy given manifest necessity | Woods argues the mistrial was improper after objection, violating double jeopardy | Woods contends alternatives existed; the court abused discretion | Yes; mistrial declared over objection violated double jeopardy (reversed) |
| Whether the trial court failed to consider feasible alternatives to mistrial | State and Woods contend the court adequately weighed options | Court should have polled jurors or given curative instructions | Yes; court abused discretion by not adequately considering alternatives (reversed) |
| Whether a curative instruction or polling could have avoided mistrial | No need for mistrial if alternatives could cure bias | Such alternatives were available and should have been used | Court failed to pursue viable alternatives (reversed) |
| Whether the in-court identification issue remained for appellate review | Identification procedures were challenged | Issue not necessary to resolve after reversal | Not addressed on the merits due to reversal |
Key Cases Cited
- Arizona v. Washington, 434 U.S. 497 (U.S. Supreme Court, 1978) (manifest necessity standard for mistrial; high deference to trial court)
- State v. Bible, 175 Ariz. 549 (Arizona Supreme Court, 1993) (trial court’s denial of mistrial affirmed where prejudice limited)
- Evans v. Abbey, 130 Ariz. 157 (Arizona Appellate, 1981) (court should inquire into juror prejudice; could have avoided mistrial)
- Jones v. Kiger, 194 Ariz. 523 (Arizona Supreme Court, 1999) (courts may admonish jurors; reconsideration of mistrial warranted when alternatives exist)
- McLaughlin v. Fahringer, 150 Ariz. 274 (Arizona Supreme Court, 1986) (real effort to determine alternatives; manifest necessity must be shown)
- Aguilar, 217 Ariz. 235 (Arizona Court of Appeals, 2007) (balancing defendant and public interests; mistrial discretion)
- Washington v. United States, 434 U.S. 497 (U.S. Supreme Court, 1978) (establishes standard for evaluating mistrial necessity)