Hoag v. New Jersey - 356 U.S. 464 (1958)
U.S. Supreme Court
Hoag v. New Jersey, 356 U.S. 464 (1958)
Hoag v. New Jersey
Argued November 19, 1957
Decided May 19, 1958
356 U.S. 464
In a New Jersey State Court, petitioner was tried and acquitted on three separate indictments (joined for trial) for statutory robbery of three persons on the same occasion. Subsequently, he was indicted, tried and convicted for robbing a fourth person during the same occurrence.
Held: his conviction did not violate the Due Process Clause of the Fourteenth Amendment. Pp. 356 U. S. 465-473.
(a) He was not put twice in jeopardy for the same crime. New Jersey construes the statute under which he was indicted as making each of the four robberies, though taking place on the same occasion, a separate offense, and nothing in the Due Process Clause prevented the State from making that construction. Pp. 356 U. S. 466-467.
(b) In the circumstances of this case, he was not deprived of due process by consecutive trials, even though the multiple offenses arose out of the same occurrence. Pp. 356 U. S. 467-470.
(c) Whether States must apply collateral estoppel in criminal trials need not be decided; because the state courts held that petitioner's acquittal did not give rise to such an estoppel, and this Court would not be justified in substituting its view as to the basis of the jury's verdict. Pp. 356 U. S. 470-472.
(d) In the circumstances of this case, he was not denied a speedy trial. P. 356 U. S. 472.
(e) The sufficiency of the evidence to support the identification of petitioner as one of the robbers is a matter solely within the province of the state courts. Pp. 356 U. S. 472-473.
21 N.J. 496, 122 A.2d 628, affirmed.