United States v. Martin Linen Supply Co.

1977-04-04

Headline: Ruling blocks Government appeals of judge-entered acquittals after jury deadlocks, holding that post-discharge acquittals under Rule 29(c) prevent retrial and bar appeals under the Constitution’s protection against being tried twice.

Holding: The Court held that a judge’s judgment of acquittal entered under Rule 29(c) after a jury is discharged for deadlock cannot be appealed by the Government because the Constitution bars retrial and successive prosecutions.

Real World Impact:

Prevents government appeals of judge-entered acquittals after jury deadlocks.
Protects defendants from retrial when a judge grants an acquittal under Rule 29(c).
Limits prosecutors’ ability to overturn post-discharge acquittals without violating double jeopardy.

Topics: double jeopardy, criminal appeals, trial procedure, jury deadlock

Summary

Background

Two commonly owned linen supply companies and their president were tried on criminal contempt charges after a jury was unable to agree on a verdict and was discharged as "hopelessly deadlocked." Six days later the companies moved under Federal Rule of Criminal Procedure 29(c) for judgments of acquittal; the District Court granted those motions about two months after the jury was dismissed. The Government tried to appeal the judgments under 18 U.S.C. § 3731, and the Fifth Circuit held the appeals were not allowed.

Reasoning

The Court asked whether a judge’s post-discharge judgment of acquittal under Rule 29(c) can be appealed by the United States. It concluded these rulings are acquittals in substance because the judge found the evidence legally insufficient to convict. Reversing such acquittals would require another trial or further fact-finding, which the Double Jeopardy protection forbids when an acquittal has been entered. The Court relied on earlier cases holding that an acquittal—regardless of the label—precludes a second prosecution and thus bars Government appeals that would allow retrial.

Real world impact

As a result, prosecutors may not appeal judge-entered acquittals entered after a jury deadlocks under Rule 29(c). Defendants gain finality from such post-discharge acquittals, and the Government cannot force a new trial by winning an appeal that would overturn those acquittals. This ruling preserves the constitutional protection against being tried twice.

Dissents or concurrances

Justice Stevens wrote separately agreeing in the judgment and stressing that the statute did not authorize appeals from acquittals; Chief Justice Burger dissented, arguing the post-deadlock context should permit appeal and retrial.