Can a defendant successfully invoke double jeopardy protection when a mistrial is declared without a clear demonstration of necessity or a fully explained rationale by the trial judge?

Washington was convicted of murdering a hotel night clerk in 1971. The Superior Court of Pima County, Arizona ordered a new trial in 1973 after discovering the prosecutor had withheld exculpatory evidence. During the second trial in January 1975, defense counsel made improper remarks about the prosecutor's previous misconduct in his opening statement. The prosecutor moved for a mistrial, which the judge granted. The Arizona Supreme Court declined to review the mistrial ruling.

Washington subsequently filed a habeas corpus petition in federal court. He argued that conducting another trial would violate the Double Jeopardy Clause of the Constitution. This petition challenged the legality of his continued detention and sought to prevent a third trial on the same charges.

The State of Arizona initially brought charges against Washington, resulting in a trial. During this trial, the Arizona court declared a mistrial. Washington sought review of this ruling from the Arizona Supreme Court, but the court declined to hear the case.

Following this, Washington filed a habeas corpus petition in the United States District Court for the District of Arizona. The District Court ruled in Washington's favor, granting the writ on the grounds that the Double Jeopardy Clause protected Washington from being tried again.

The State of Arizona appealed this decision to the Court of Appeals for the Ninth Circuit. The Ninth Circuit affirmed the District Court's ruling, maintaining that Washington could not be retried.

Subsequently, the case reached the United States Supreme Court through a writ of certiorari, likely filed by the State of Arizona seeking to overturn the lower courts' decisions.

(Stevens, J.)

No. A defendant cannot successfully invoke double jeopardy protection when a mistrial is declared without a clear demonstration of necessity or a fully explained rationale by the trial judge. The trial judge's decision to declare a mistrial based on the assessment of prejudicial impact from improper argument is entitled to great deference. Reviewing courts must accord substantial deference to such determinations, recognizing the trial judge's superior position to evaluate the potential bias of jurors. The absence of an explicit finding of "manifest necessity" does not automatically render a mistrial ruling constitutionally defective. Rather, if the record provides sufficient justification for the state-court ruling, the decision remains valid. This principle acknowledges the complex and often rapid nature of trial proceedings, where judges must make swift decisions to ensure fairness. The failure to explain a ruling more completely does not, in itself, create a constitutional defect. Instead, the focus is on whether the record, taken as a whole, supports the judge's decision. This approach balances the need for judicial efficiency with the protection of defendants' rights, recognizing that a trial judge's firsthand assessment of courtroom dynamics and potential jury prejudice is uniquely valuable. Consequently, while a clear demonstration of necessity is ideal, its absence does not automatically invalidate a mistrial declaration or trigger double jeopardy protections when the overall context supports the judge's decision.

Dissent (White, J.) The case should be remanded to the Court of Appeals to determine whether the use of an incorrect legal standard was sufficiently indicated by the record. This approach would ensure a thorough review of the trial court's decision-making process and potentially reveal any procedural errors that may have influenced the outcome. Proper scrutiny of the legal standards applied is crucial for maintaining the integrity of the judicial process and protecting defendants' rights.

Dissent (Marshall, J.) The absence of any finding of 'manifest necessity' or exploration of alternatives to a mistrial in the record should preclude retrial under the Double Jeopardy Clause. This omission represents a fundamental flaw in the trial court's decision-making process. The Double Jeopardy Clause serves as a critical safeguard against repeated prosecutions, and its protections should not be circumvented without clear justification. Allowing retrial in this case without proper documentation of manifest necessity sets a dangerous precedent that could erode defendants' constitutional protections against double jeopardy.