Lamar Evans, Petitioner v. Michigan (568 U.S. 313)
U.S. Supreme Court · decided February 20, 2013 · Supreme Court Database (Spaeth)
- Citation
- 568 U.S. 313 · 133 S. Ct. 1069
- Decided
- February 20, 2013
- Term
- October Term 2012
- Vote
- 8–1
- Majority author
- Justice Sotomayor
- Issue area
- Criminal Procedure
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Sotomayor delivered the opinion of the Court. When the State of Michigan rested its case at petitioner Lamar Evans’ arson trial, the court entered a directed verdict of acquittal, based upon its view that the State had not provided sufficient evidence of a particular element of the offense. It turns out that the unproven “element” was not actually a required element at all. We must decide whether an erroneous acquittal such as this nevertheless constitutes an acquittal for double jeopardy purposes, which would mean that Evans could not be retried. This Court has previously held that a judicial acquittal premised upon a “misconstruction” of a criminal statute is an “acquittal on the merits [that] bars retrial.” Arizona v. Rumsey, 467 U. S. 203, 211 (1984). Seeing no meaningful constitutional distinction between a trial court’s “misconstruction” of a statute and its erroneous addition of a statutory element, we hold that a midtrial acquittal in these circumstances is an acquittal for double jeopardy purposes as well. I The State charged Evans with burning “other real property,” a violation of Mich. Comp. Laws § 750.73 (1981). The State’s evidence at trial suggested that Evans had burned down an unoccupied house. At the close of the State’s case, however, Evans moved for a directed verdict of acquittal. He pointed the court to the applicable Michigan Criminal Jury…
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