OPINION OF THE COURT
YEAGER V. UNITED STATES
557 U. S. ____ (2009)
SUPREME COURT OF THE UNITED STATES
NO. 08-67
F. SCOTT YEAGER, PETITIONER
v. UNITED
STATES
on writ of certiorari to the united states court of
appeals for the fifth circuit
[June 18, 2009]
Justice Stevens delivered the
opinion of the Court.
In
Dunn v.
United
States,
284 U. S. 390, 393 (1932), the Court,
speaking through Justice Holmes, held that a logical inconsistency
between a guilty verdict and a verdict of acquittal does not impugn
the validity of either verdict. The question presented in this case
is whether an apparent inconsistency between a jury’s verdict of
acquittal on some counts and its failure to return a verdict on
other counts affects the preclusive force of the acquittals under
the Double Jeopardy Clause of the Fifth Amendment. We hold that it
does not.
I
In 1997, Enron Corporation
(Enron) acquired a telecommunications business that it expanded and
ultimately renamed Enron Broadband Services (EBS). Petitioner F.
Scott Yeager served as Senior Vice President of Strategic
Development for EBS from October 1, 1998, until his employment was
terminated a few months before Enron filed for bankruptcy on
December 2, 2001. During his tenure, petitioner played an active
role in EBS’s attempt to develop a nationwide fiber-optic
telecommunications system called the Enron Intelligent Network
(EIN).
In the summer of 1999, Enron
announced that EBS would become a “ ‘core’ ” Enron
business and a major part of its overall strategy. App. 11.
Thereafter, Enron issued press releases touting the advanced
capabilities of EIN and claiming that the project was
“ ‘lit,’ ” or operational.
Id., at 10. On
January 20, 2000, at the company’s annual equity analyst
conference, petitioner and others allegedly made false and
misleading statements about the value and performance of the EIN
project. On January 21, 2000, the price of Enron stock rose from
$54 to $67. The next day it reached $72. At that point petitioner
sold more than 100,000 shares of Enron stock that he had received
as part of his compensation. During the next several months
petitioner sold an additional 600,000 shares. All told,
petitioner’s stock sales generated more than $54 million in
proceeds and $19 million in personal profit. As for the EIN
project, its value turned out to be illusory. The “intelligent”
network showcased to the public in the press releases and at the
analyst conference was riddled with technological problems and
never fully developed.
On November 5, 2004, a grand jury returned a
“Fifth Superseding Indictment” charging petitioner with 126 counts
of five federal offenses: (1) conspiracy to commit securities and
wire fraud; (2) securities fraud; (3) wire fraud; (4) insider
trading; and (5) money laundering.[
Footnote 1] The Government’s theory of prosecution was
that petitioner—acting in concert with other Enron
executives—purposefully deceived the public about the EIN project
in order to inflate the value of Enron’s stock and, ultimately, to
enrich himself.[
Footnote 2]
Id., at 6.
Count 1 of the indictment described in some
detail the alleged conspiracy to commit securities fraud and wire
fraud and included as overt acts the substantive offenses charged
in counts 2 through 6. Count 2, the securities fraud count, alleged
that petitioner made false and misleading statements at the January
20, 2000, analyst conference or that he failed to state facts
necessary to prevent statements made by others from being
misleading. Counts 3 through 6 alleged that petitioner and others
committed four acts of wire fraud when they issued four EBS-related
press releases in 2000. Counts 27 through 46, the insider trading
counts, alleged that petitioner made 20 separate sales of Enron
stock “while in the possession of material non-public information
regarding the technological capabilities, value, revenue and
business performance of [EBS].”
Id., at 31. And counts 67
through 165, the money laundering counts, described 99 financial
transactions involving petitioner’s use of the proceeds of his
sales of Enron stock, which the indictment characterized as
“criminally derived property.”
Id., at 37. To simplify our
discussion, we shall refer to counts 1 through 6 as the “fraud
counts” and the remaining counts as the “insider trading
counts.”
The trial lasted 13 weeks. After four days of
deliberations, the jury notified the court that it had reached
agreement on some counts but had deadlocked on others. The judge
then gave the jury an
Allen charge, see
Allen
v
. United States, 164 U. S. 492, 501–502
(1896), urging the jurors to reexamine the grounds for their
opinions and to continue deliberations “until the end of the day”
to achieve a final verdict on all counts. Tr. 13724 (July 20,
2005). When the jury failed to break the deadlock, the court told
the jurors that it would “take their verdict” instead of prolonging
deliberations.
Id., at 13725. The jury acquitted
petitioner on the fraud counts but failed to reach a verdict on the
insider trading counts. The court entered judgment on the
acquittals and declared a mistrial on the hung counts.
On November 9, 2005, the Government obtained a
new indictment against petitioner. This “Eighth Superseding
Indictment” recharged petitioner with some, but not all, of the
insider trading counts on which the jury had previously hung. App.
188. The new indictment refined the Government’s case: Whereas the
earlier indictment had named multiple defendants, the new
indictment dealt exclusively with petitioner. And instead of
alleging facts implicating a broader fraudulent scheme, the new
indictment focused on petitioner’s knowledge of the EIN project and
his failure to disclose that information to the public before
selling his Enron stock.
Petitioner moved to dismiss all counts in the
new indictment on the ground that the acquittals on the fraud
counts precluded the Government from retrying him on the insider
trading counts.[
Footnote 3] He
argued that the jury’s acquittals had necessarily decided that he
did not possess material, nonpublic information about the
performance of the EIN project and its value to Enron. In
petitioner’s view, because reprosecution for insider trading would
require the Government to prove that critical fact, the
issue-preclusion component of the Double Jeopardy Clause barred a
second trial of that issue and mandated dismissal of all of the
insider trading counts.
The District Court denied the motion. After
reviewing the trial record, the court disagreed with petitioner’s
reading of what the jury necessarily decided. In the court’s
telling, the jury likely concluded that petitioner “did not
knowingly and willfully participate in the scheme to defraud
described in the conspiracy, securities fraud, and wire fraud
counts.” 446 F. Supp. 2d 719, 735 (SD Tex. 2006). The court
therefore concluded that the question whether petitioner possessed
insider information was not necessarily resolved in the first trial
and could be litigated anew in a second prosecution.
The Court of Appeals disagreed with the
District Court’s analysis of the record, but nevertheless affirmed.
It reasoned that petitioner “did not dispute” the Government’s
theory that he “helped shape the message” of the allegedly
fraudulent presentations made at the analyst conference, and
therefore rejected the District Court’s conclusion that the jury
had “acquitted [petitioner] on the groun[d] that he did not
participate in the fraud.” 521 F. 3d 367, 377 (CA5 2008).
Based on its independent review of the record, the Court of Appeals
instead concluded that “the jury must have found when it acquitted
[petitioner] that [he] did not have any insider information that
contradicted what was presented to the public.”
Id., at
378. The court acknowledged that this factual determination would
normally preclude the Government from retrying petitioner for
insider trading or money laundering.
The court was nevertheless persuaded that a
truly rational jury, having concluded that petitioner did not have
any insider information, would have
acquitted him on the
insider trading counts. That the jury failed to acquit, and instead
hung on those counts, was pivotal in the court’s issue-preclusion
analysis. Considering “the hung counts along with the acquittals,”
the court found it impossible “to decide with any certainty what
the jury necessarily determined.”
Ibid. Relying on Circuit
precedent,
United States v.
Larkin, 605
F. 2d 1360 (1979), the court concluded that the conflict
between the acquittals and the hung counts barred the application
of issue preclusion in this case. 521 F. 3d, at 378–379.
Several courts have taken the contrary view
and have held that a jury’s failure to reach a verdict on some
counts should play no role in determining the preclusive effect of
an acquittal. See
United States v.
Ohayon, 483
F. 3d 1281 (CA11 2007);
United States v.
Romeo, 114 F. 3d 141 (CA9 1997);
United
States v.
Bailin, 977 F. 2d 270 (CA7 1992);
United States v.
Frazier, 880 F. 2d 878 (CA6
1989). Others have sided with the Court of Appeals. See
United
States v.
Howe, 538 F. 3d 820 (CA8 2008);
United States v.
Aguilar-Aranceta, 957 F. 2d
18 (CA1 1992);
United States v.
White, 936
F. 2d 1326 (CADC 1991). We granted certiorari to resolve the
conflict, 555 U. S. ___ (2008), and now reverse.
II
The Double Jeopardy Clause of the
Fifth Amendment provides: “[N]or shall any person be subject for
the same offence to be twice put in jeopardy of life or limb.”
While we have decided an
exceptionally large number of cases interpreting this provision,
see,
e.g.,
United States v.
DiFrancesco,
449 U. S. 117,
126–127 (1980) (collecting cases), most of our decisions have found
more guidance in the common-law ancestry of the Clause than in its
brief text. Thus, for example, while the risk of being fined or
imprisoned implicates neither “life” nor “limb,” our early cases
held that double jeopardy protection extends to punishments that
are not “
positively covered by the
language of
[the] amendment.”
Ex parte Lange, 18 Wall. 163, 170
(1874). As we explained, “[i]t is very clearly the
spirit
of the instrument to prevent a second punishment under judicial
proceedings for the same crime, so far as the common law gave that
protection.”
Ibid.
Our cases have recognized that the Clause
embodies two vitally important interests. The first is the “deeply
ingrained” principle that “the State with all its resources and
power should not be allowed to make repeated attempts to convict an
individual for an alleged offense, thereby subjecting him to
embarrassment, expense and ordeal and compelling him to live in a
continuing state of anxiety and insecurity, as well as enhancing
the possibility that even though innocent he may be found guilty.”
Green v.
United States,
355 U. S. 184, 187–188
(1957); see
Benton v.
Maryland,
395 U. S. 784, 795–795
(1969);
DiFrancesco, 449 U. S., at 127–128. The second
interest is the preservation of “the finality of judgments.”
Crist v.
Bretz,
437 U. S. 28, 33
(1978).
The first interest is implicated whenever the
State seeks a second trial after its first attempt to obtain a
conviction results in a mistrial because the jury has failed to
reach a verdict. In these circumstances, however, while the
defendant has an interest in avoiding multiple trials, the Clause
does not prevent the Government from seeking to reprosecute.
Despite the argument’s textual appeal, we have held that the second
trial does not place the defendant in jeopardy “twice.”
Richardson v.
United States,
468 U. S. 317, 323 (1984); see 3 J.
Story, Commentaries on the Constitution §1781, pp. 659–660 (1833).
Instead, a jury’s inability to reach a decision is the kind of
“manifest necessity” that permits the declaration of a mistrial and
the continuation of the initial jeopardy that commenced when the
jury was first impaneled. See
Arizona v.
Washington,
434 U. S. 497, 505–506
(1978);
United States v.
Perez, 9 Wheat. 579, 580
(1824). The “interest in giving the prosecution one complete
opportunity to convict those who have violated its laws” justifies
treating the jury’s inability to reach a verdict as a nonevent that
does not bar retrial.
Washington, 434 U. S., at 509.
While the case before us involves a mistrial
on the insider trading counts, the question presented cannot be
resolved by asking whether the Government should be given one
complete opportunity to convict petitioner on those charges.
Rather, the case turns on the second interest at the core of the
Clause. We must determine whether the interest in preserving the
finality of the jury’s judgment on the fraud counts, including the
jury’s finding that petitioner did not possess insider information,
bars a retrial on the insider trading counts. This requires us to
look beyond the Clause’s prohibition on being put in jeopardy
“twice”; the jury’s acquittals unquestionably terminated
petitioner’s jeopardy with respect to the issues finally decided in
those counts. The proper question, under the Clause’s text, is
whether it is appropriate to treat the insider trading charges as
the “same offence” as the fraud charges. Our opinion in
Ashe v.
Swenson,
397 U. S. 436 (1970),
provides the basis for our answer.
In
Ashe, we squarely held that the
Double Jeopardy Clause precludes the Government from relitigating
any issue that was necessarily decided by a jury’s acquittal in a
prior trial. In that case, six poker players were robbed by a group
of masked men. Ashe was charged with—and acquitted of—robbing
Donald Knight, one of the six players. The State sought to retry
Ashe for the robbery of another poker player only weeks after the
first jury had acquitted him. The second prosecution was
successful: Facing “substantially stronger” testimony from
“witnesses [who] were for the most part the same,”
id., at
439–440, Ashe was convicted and sentenced to a 35-year prison term.
We concluded that the subsequent prosecution was constitutionally
prohibited. Because the only contested issue at the first trial was
whether Ashe was one of the robbers, we held that the jury’s
verdict of acquittal collaterally estopped the State from trying
him for robbing a different player during the same criminal
episode.
Id., at 446. We explained that “when an issue of
ultimate fact has once been determined by a valid and final
judgment” of acquittal, it “cannot again be litigated” in a second
trial for a separate offense.
Id., at 443.[
Footnote 4] To decipher what a jury has
necessarily decided, we held that courts should “examine the record
of a prior proceeding, taking into account the pleadings, evidence,
charge, and other relevant matter, and conclude whether a rational
jury could have grounded its verdict upon an issue other than that
which the defendant seeks to foreclose from consideration.”
Id., at 444 (internal quotation marks omitted). We
explained that the inquiry “must be set in a practical frame and
viewed with an eye to all the circumstances of the proceedings.”
Ibid. (quoting
Sealfon v.
United States,
332 U. S. 575,
579 (1948) (internal quotation marks omitted)).
Unlike
Ashe, the case before us today
entails a trial that included multiple counts rather than a trial
for a single offense. And, while
Ashe involved an
acquittal for that single offense, this case involves an acquittal
on some counts and a mistrial declared on others. The reasoning in
Ashe is nevertheless controlling because, for double
jeopardy purposes, the jury’s inability to reach a verdict on the
insider trading counts was a nonevent and the acquittals on the
fraud counts are entitled to the same effect as Ashe’s
acquittal.
As noted above, see
supra, at 4, the
Court of Appeals reasoned that the hung counts must be considered
to determine what issues the jury decided in the first trial.
Viewed in isolation, the court explained, the acquittals on the
fraud charges would preclude retrial because they appeared to
support petitioner’s argument that the jury decided he lacked
insider information. 521 F. 3d, at 378. Viewed alongside the
hung counts, however, the acquittals appeared less decisive. The
problem, as the court saw it, was that, if “the jury found that
[petitioner] did not have insider information, then the jury,
acting rationally, would also have acquitted [him] of the insider
trading counts.”
Ibid. The fact that the jury hung was a
logical wrinkle that made it impossible for the court “to decide
with any certainty what the jury necessarily determined.”
Ibid. Because petitioner failed to show what the jury
decided,
id., at 380, the court refused to find the
Government precluded from pursuing the hung counts in a new
prosecution.
The Court of Appeals’ issue-preclusion
analysis was in error. A hung count is not a “relevant” part of the
“record of [the] prior proceeding.” See
Ashe, 397 U. S.,
at 444 (internal quotation marks omitted). Because a jury speaks
only through its verdict, its failure to reach a verdict cannot—by
negative implication—yield a piece of information that helps put
together the trial puzzle. A mistried count is therefore nothing
like the other forms of record material that
Ashe
suggested should be part of the preclusion inquiry.
Ibid.
; see also Black’s Law Dictionary 1301 (8th
ed. 2004) (defining “record” as the “official report of the
proceedings in a case, including the filed papers, verbatim
transcript of the trial or hearing (if any), and tangible
exhibits”). Unlike the pleadings, the jury charge, or the evidence
introduced by the parties, there is no way to decipher what a hung
count represents. Even in the usual sense of “relevance,” a hung
count hardly “make[s] the existence of any fact … more probable or
less probable.” Fed. Rule Evid. 401. A host of reasons—sharp
disagreement, confusion about the issues, exhaustion after a long
trial, to name but a few—could work alone or in tandem to cause a
jury to hang.[
Footnote 5] To
ascribe meaning to a hung count would presume an ability to
identify which factor was at play in the jury room. But that is not
reasoned analysis; it is guesswork.[
Footnote 6] Such conjecture about possible reasons for a
jury’s failure to reach a decision should play no part in assessing
the legal consequences of a unanimous verdict that the jurors did
return.
A contrary conclusion would require
speculation into what transpired in the jury room. Courts properly
avoid such explorations into the jury’s sovereign space, see
United States v.
Powell,
469 U.
S. 57, 66 (1984); Fed. Rule Evid. 606(b), and for good reason.
The jury’s deliberations are secret and not subject to outside
examination. If there is to be an inquiry into what the jury
decided, the “evidence should be confined to the points in
controversy on the former trial, to the testimony given by the
parties, and to the questions submitted to the jury for their
consideration.”
Packet Co. v.
Sickles, 5 Wall.
580, 593 (1866); see also
Vaise v.
Delaval, 99
Eng. Rep. 944 (K. B. 1785) (Lord Mansfield, C. J.) (refusing
to rely on juror affidavits to impeach a verdict reached by a coin
flip); J. Wigmore, Evidence §2349, pp. 681–690, and n. 2
(McNaughton rev. ed. 1961 and Supp. 1991).
Accordingly, we hold that the consideration of
hung counts has no place in the issue-preclusion analysis. Indeed,
if it were relevant, the fact that petitioner has already survived
one trial should be a factor cutting in favor of, rather than
against, applying a double jeopardy bar. To identify what a jury
necessarily determined at trial, courts should scrutinize a jury’s
decisions, not its failures to decide. A jury’s verdict of
acquittal represents the community’s collective judgment regarding
all the evidence and arguments presented to it. Even if the verdict
is “based upon an egregiously erroneous foundation,”
Fong
Foo v.
United States,
369 U. S. 141, 143
(1962)
(per curiam), its finality is unassailable. See,
e.g.,
Washington, 434 U. S., at 503;
Sanabria v.
United States,
437 U. S. 54, 64 (1978).
Thus, if the possession of insider information was a critical issue
of ultimate fact in all of the charges against petitioner, a jury
verdict that necessarily decided that issue in his favor protects
him from prosecution for any charge for which that is an essential
element.
III
The Government relies heavily on
two of our cases,
Richardson v.
United States,
468 U. S. 317, and
United
States v.
Powell,
469 U.
S. 57, to argue that it is entitled to retry petitioner on the
insider trading counts. Neither precedent can bear the weight the
Government places on it.
In
Richardson, the
defendant was indicted on three counts of narcotics violations. The
jury acquitted him on one count but hung on the others. Richardson
moved to bar retrial on the hung counts, insisting that
reprosecution would place him twice in jeopardy for the same
offense. Unlike petitioner in this case, Richardson did not argue
that retrial was barred because the jury’s verdict of acquittal
meant that it necessarily decided an essential fact in his favor.
He simply asserted that the hung counts, standing alone, shielded
him from reprosecution. We disagreed and held that “the protection
of the Double Jeopardy Clause by its terms applies only if there
has been some event, such as an acquittal, which terminates the
original jeopardy.” 468 U. S., at 325. “[T]he failure of the jury
to reach a verdict,” we explained, “is not an event which
terminates jeopardy.”
Ibid. From this the Government
extrapolates the altogether different principle that retrial is
always permitted whenever a jury convicts on some counts
and hangs on others. Brief for United States 23–24. But
Richardson was not so broad. Rather, our conclusion was a
rejection of the argument—similar to the one the Government urges
today—that a mistrial is an event of significance. In so holding,
we did not open the door to using a mistried count to ignore the
preclusive effect of a jury’s acquittal.
The Government next contends that an acquittal
can never preclude retrial on a mistried count because it would
impute irrationality to the jury in violation of the rule
articulated in
Powell,
469 U.
S. 57. In
Powell, the defendant was charged with
various drug offenses. The jury acquitted Powell of the substantive
drug charges but convicted her of using a telephone in
“ ‘committing and in causing and facilitating’ ” those
same offenses.
Id., at 59–60. Powell attacked the verdicts
on appeal as irrationally inconsistent and urged the reversal of
her convictions. She insisted that “collateral estoppel should
apply to verdicts rendered by a single jury, to preclude acceptance
of a guilty verdict on a telephone facilitation count where the
jury acquits the defendant of the predicate felony.”
Id.,
at 64. We rejected this argument, reasoning that issue preclusion
is “predicated on the assumption that the jury acted rationally.”
Id., at 68.
Arguing that a jury that acquits on some
counts while inexplicably hanging on others is not rational, the
Government contends that issue preclusion is as inappropriate in
this case as it was in
Powell. There are two serious flaws
in this line of reasoning. First, it takes
Powell’s
treatment of inconsistent
verdicts and imports it into an
entirely different context involving both
verdicts and
seemingly inconsistent
hung counts. But the situations are
quite dissimilar. In
Powell, respect for the jury’s
verdicts counseled giving each verdict full effect, however
inconsistent. As we explained, the jury’s verdict “brings to the
criminal process, in addition to the collective judgment of the
community, an element of needed finality.”
Id., at 67. By
comparison, hung counts have never been accorded respect as a
matter of law or history, and are not similar to jury verdicts in
any relevant sense. By equating them, the Government’s argument
fails. Second, the Government’s reliance on
Powell assumes
that a mistried count can, in context, be evidence of
irrationality. But, as we explained above, see
supra, at
7–8, the fact that a jury hangs is evidence of nothing—other than,
of course, that it has failed to decide anything. By relying on
hung counts to question the basis of the jury’s verdicts, the
Government violates the very assumption of rationality it invokes
for support.
At bottom, the Government misreads our cases
that have rejected attempts to question the validity of a jury’s
verdict. In
Powell and, before that, in
Dunn,
284 U. S. 390, we were faced with jury
verdicts that, on their face, were logically inconsistent and yet
we refused to impugn the legitimacy of either verdict. In this
case, there is merely a
suggestion that the jury may have
acted irrationally. And instead of resting that suggestion on a
verdict, the Government relies on a hung count, the thinnest reed
of all. If the Court in
Powell and
Dunn declined
to use a clearly inconsistent verdict to second-guess the soundness
of another verdict, then,
a fortiori, a potentially
inconsistent hung count could not command a different result.
IV
One final matter requires
discussion. The Government argues that even if we conclude (as we
do) that acquittals can preclude retrial on counts on which the
same jury hangs, we should nevertheless affirm the judgment of the
Court of Appeals because petitioner failed to show that the jury
necessarily resolved in his favor an issue of ultimate fact that
the Government must prove in order to convict him of insider
trading and money laundering. See Brief for United States 41–45.
Given the length and complexity of the proceedings, this factual
dispute is understandable. The District Court and Court of Appeals
each read the record differently, disagreeing as to what the jury
necessarily decided in its acquittals. Compare 446 F. Supp.
2d, at 735 (“[T]he jury necessarily determined that Defendant
Yeager did not knowingly and willfully participate or agree to
participate in a scheme to defraud in connection with the alleged
false statements or material omissions made at the analyst
conference and press releases”), with 521 F. 3d, at 378
(“[T]he jury must have found when it acquitted Yeager that Yeager
himself did not have any insider information that contradicted what
was presented to the public”). Our grant of certiorari was based on
the assumption that the Court of Appeals’ interpretation of the
record was correct. We recognize the Government’s right, as the
prevailing party in the Court of Appeals, to “defend its judgment
on any ground properly raised below whether or not that ground was
relied upon, rejected, or even considered by the District Court or
the Court of Appeals.”
Washington v.
Confederated
Bands and Tribes of Yakima Nation,
439 U. S. 463, 476,
n. 20 (1979). But we decline to engage in a fact-intensive
analysis of the voluminous record, an undertaking unnecessary to
the resolution of the narrow legal question we granted certiorari
to answer. If it chooses, the Court of Appeals may revisit its
factual analysis in light of the Government’s arguments before this
Court.
V
The judgment is reversed, and the
case is remanded to the Court of Appeals for further proceedings
consistent with this opinion.
It is so ordered.
Footnote 1
See 18 U. S. C. §371 (conspiracy to
commit fraud against the United States); 15 U. S. C. §78j(b)
(1994 ed.), §78ff (2000 ed.), and 17 CFR §240.10b–5 (2004)
(securities fraud); 18 U. S. C. §1343 (2000 ed.) (wire fraud);
15 U. S. C. §78j(b) (1994 ed.), §78ff (2000 ed.), and 17 CFR
§240.10b–5–1 (insider trading); 18 U. S. C. §1957 (money
laundering).
Footnote 2
While petitioner was charged with 126
counts, the indictment included 176 counts in all, covering conduct
by executives purportedly involved in the alleged fraud.
Footnote 3
Petitioner had also moved to dismiss the
relevant counts in the earlier indictment in response to the
Government’s assertion that it could reprosecute petitioner for the
previously hung counts under that indictment as well. See 521
F. 3d 367, 370, n. 4 (CA5 2008).
Footnote 4
Although the doctrine of collateral
estoppel had developed in civil litigation, we had already extended
it to criminal proceedings when Ashe was decided. The
justification for this application was first offered by Justice
Holmes, who observed that “[i]t cannot be that the safeguards of
the person, so often and so rightly mentioned with solemn
reverence, are less than those that protect from a liability in
debt.”
United States v.
Oppenheimer,
242 U. S. 85, 87 (1916).
Currently, the more descriptive term “issue preclusion” is often
used in lieu of “collateral estoppel.” See Restatement (Second) of
Judgments §27 (1980).
Footnote 5
Indeed, there were many indications that the
jury in this case could have been exhausted after the 13-week
trial. See Reply Brief for Petitioner 9–10 (cataloging numerous
“statements on the record [that] reveal the very real possibility
that the jurors cut their deliberations short out of
exhaustion”).
Footnote 6
It would also require too much of the
defendant. To preclude retrial, he must show that the jury
necessarily decided an issue in his favor. Yet, to borrow from the
Court of Appeals, “[b]ecause it is impossible to determine why [a]
jury hung,” 521 F. 3d, at 379, the defendant will have to
rebut all inferences about what
may have motivated the
jury to hang without the ability to seek conclusive proof. See Fed.
Rule Evid. 606(b). There is no reason to impose such a burden on a
defendant.
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