State v. Hunter
2012 Minn. App. LEXIS 61
Minn. Ct. App.2012Background
- Hunter struck a pedestrian in a crosswalk, left the scene, and the victim died a week later.
- Hunter was charged with two felonies for leaving the scene of an accident involving death and one misdemeanor for driving after license suspension.
- The jury deliberated for nearly three days without a verdict; the district court declared a mistrial sua sponte after a deadlock.
- Hunter moved to dismiss on double jeopardy grounds; the district court denied, ruling consent to the mistrial and manifest necessity.
- On appeal, Hunter challenges the mistrial declaration and the denial of double jeopardy relief; the court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the mistrial declaration appropriate? | Hunter | Hunter | No abuse; manifest necessity. |
Key Cases Cited
- State v. White, 369 N.W.2d 301 (Minn.App.1985) (implied consent to mistrial can waive double jeopardy claim)
- State v. Fuller, 374 N.W.2d 722 (Minn.1985) (manifest necessity required for retrial after mistrial)
- State v. Gouleed, 720 N.W.2d 794 (Minn.2006) (review of sua sponte mistrial decision is abuse of discretion)
- State v. Yeboah, 691 N.W.2d 87 (Minn.App.2005) (great deference to trial court when jury deadlocked)
- Arizona v. Washington, 434 U.S. 497 (U.S. 1978) (manifest necessity standard for mistrial; juror deadlock)
- State v. Soyke, 585 N.W.2d 418 (Minn.App.1998) (manifest necessity in mistrial context)