Simpson v. Florida

Background

In 1966 two armed men robbed a store manager and a customer in Jacksonville, Florida. The man accused here was tried in 1967 for robbing the manager and convicted, but that conviction was reversed on appeal because the judge failed to instruct the jury about a lesser charge. He was retried in 1968 on the manager charge and acquitted. Later he was charged and tried for robbing the customer, convicted by a jury, and given a 30-year sentence; he appealed while this Court decided a related case, Ashe v. Swenson.

Reasoning

The Court examined whether the constitutional protection against being tried twice includes a rule that prevents relitigation of issues already decided by a jury — in this case, the defendant’s identity as one of the robbers. Relying on Ashe, the Court held that a prior acquittal can bar later prosecution on the same disputed issue if the earlier jury could only have decided the case by resolving that issue. The Florida court had instead treated earlier verdicts as allowing a kind of double estoppel against the defendant; the Supreme Court found that reasoning incorrect and vacated the state court judgment, sending the case back for further proceedings consistent with this opinion.

Real world impact

The decision requires courts to look closely at prior trial records when a defendant claims a prior acquittal bars a new prosecution on the same facts. It strengthens protections for people who face multiple prosecutions arising from the same incident, while leaving further factual development and final resolution to the lower courts.

Dissents or concurrances

Justice Brennan (joined by Justice Douglas) said he would bar the later prosecution on these facts; the Chief Justice and Justice Blackmun dissented as in Ashe.