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Arizona v. Washington

Citation. Arizona v. Washington, 434 U.S. 497, 98 S. Ct. 824, 54 L. Ed. 2d 717, 1978)
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Brief Fact Summary.

Defendant’s new trial was held to be a mistrial without express explanation from the trial judge.

Synopsis of Rule of Law.

“The overriding interest in the evenhanded administration of justice requires that [the court] accord the highest degree of respect to the trial judge’s evaluation of the likelihood that the impartiality of one or more jurors may have been affected by the improper comment.”


Respondent, previously convicted for murder, was undergoing a new trial because the prosecutor had withheld exculpatory evidence in the first. The respondent’s counsel attacked the prosecution in his opening statement for withhold evidence. The judge granted the prosecutor’s motion for a mistrial, but did not specify that there was a “manifest necessity” or that he found alternate solutions inadequate.


“[W]hether the record reflects the kind of ‘necessity’ for the mistrial ruling that will avoid a valid plea of double jeopardy.”

“[W]hether the plea must nevertheless be allowed because the Arizona trial judge did not fully explain the reasons for his mistrial ruling.”


The Supreme Court deferred to the trial judge on this matter, operating on the presumption that “the difficulty which led to the mistrial in this case also falls in an area where the trial judge’s determination is entitles to special respect.” The Court also did not find that the judge acted irrationally or irresponsibly. Since the judge exercised “sound discretion” in “handling the sensitive problem of possible juror bias created by the improper comment.

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