State v. Manatau
Annotate this CaseThe State charged Defendant with various crimes, including aggravated burglary and aggravated assault. After the jury was empaneled and sworn and on the second day of trial, the trial judge announced that she was recusing herself and declaring a mistrial. The case was subsequently reassigned for retrial under a new judge. Defendant moved to dismiss the charges against him on the grounds of double jeopardy. The trial court denied the motion, concluding that the mistrial did not act as an acquittal because the mistrial was legally necessary. The Supreme Court reversed, holding (1) the burden to create a record for and sufficiently justify the mistrial fell on the trial court and the State, and, in this case, the legal necessity for a mistrial was not established on the record; and (2) Utah’s constitutional protections against double jeopardy precluded a second trial under such circumstances.
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