Smith v. Massachusetts
| Smith v. Massachusetts | |
|---|---|
| Decided February 22, 2005 | |
| Full case name | Smith v. Massachusetts |
| Citations | 543 U.S. 462 (more) |
| Holding | |
| Submitting a count to the jury after the judge has granted a mid-trial acquittal subjects a defendant to further factfinding proceedings going to guilt or innocence and violates the Double Jeopardy Clause. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Scalia, joined by Stevens, O’Connor, Souter, Thomas |
| Dissent | Ginsburg, joined by Rehnquist, Kennedy, Breyer |
| Laws applied | |
| Double Jeopardy Clause | |
Smith v. Massachusetts, 543 U.S. 462 (2005), was a United States Supreme Court case in which the court held that submitting a count to the jury after the judge has granted a mid-trial acquittal subjects a defendant to further factfinding proceedings going to guilt or innocence and violates the Double Jeopardy Clause.[1][2][3][4]
Background
Smith was tried before a Massachusetts jury on charges related to a shooting, including unlawful possession of a firearm. At the conclusion of the prosecution's case, Smith moved for a not-guilty finding on the firearm count because "the evidence [was] insufficient as a matter of law to sustain a conviction". The trial judge granted the motion, finding no evidence to support the requirement of the unlawful possession count that the firearm have a barrel shorter than 16 inches. The prosecution rested, and the trial proceeded on the other counts. Before closing argument, the prosecution argued that under Massachusetts precedent, the victim's testimony that the defendant shot him with a "pistol" or "revolver" sufficed to establish barrel length. The judge "reversed" her previous ruling, allowing the firearm count to go to the jury. The jury convicted petitioner on all counts. In affirming, the Massachusetts Appeals Court held that the Double Jeopardy Clause was not implicated because the trial judge's correction of her ruling had not subjected petitioner to a second prosecution or proceeding, and held that the Massachusetts criminal rule used for the acquittal did not prohibit the judge from reconsidering her decision.[1]
The Supreme Court granted certiorari.[1]
Opinion of the court
The Supreme Court issued an opinion on February 22, 2005.[1]
Later developments
References
- ^ a b c d Smith v. Massachusetts, 543 U.S. 462 (2005).
- ^ Staskiews, Mike. "Clearing the Murky Waters of the Sargasso Sea: The Supreme Court's Upholding of Acquittals as Final in Smith v. Massachusetts." Gonz. L. Rev. 41 (2005): 391.
- ^ Durham, Andrew S. "State v. Davenport: The Louisiana Supreme Court Ignores Federal Constitutional Double Jeopardy Protections in Favor of Criminal Reprosecution." Tul. L. Rev. 89 (2014): 909.
- ^ Deterding, Cody (April 1, 2024). "On the Hook: Venue, Vicinage, and Double Jeopardy's Relationship with Modern Data Crimes". Missouri Law Review. 89 (2). ISSN 0026-6604.
External links
This article incorporates written opinion of a United States federal court. As a work of the U.S. federal government, the text is in the public domain.