Sanabria v. United States
Headline: Double jeopardy blocks Government appeal and retry after trial judge struck numbers evidence, protecting defendant from reprosecution for the same illegal gambling business and limiting appeals from midtrial rulings.
Holding: The Court holds that an acquittal after exclusion of evidence bars retrial on the same illegal gambling business, reversing the court of appeals and preventing the Government’s midtrial appeal from proceeding.
- Bars retrial after acquittal for the same statutory offense.
- Limits Government appeals from midtrial rulings producing acquittals.
- Protects defendants from multiple prosecutions for one gambling business.
Summary
Background
Thomas Sanabria, one of several people charged under a federal law banning participation in an “illegal gambling business,” went to trial on a single count that described both horse betting and numbers betting. After the Government’s case, the judge struck all evidence about numbers betting and then granted Sanabria a judgment of acquittal because the remaining proof did not show his connection to the horse-betting operation. The Government moved for reconsideration and appealed to the Court of Appeals, which allowed an appeal and ordered a new trial on the numbers theory.
Reasoning
The Supreme Court addressed whether the Government may appeal midtrial rulings that lead to an acquittal without violating the Fifth Amendment’s Double Jeopardy Clause. The Court, in an opinion by Justice Marshall, held that an acquittal — even one produced after an erroneous exclusion of evidence — bars retrial on the same statutory offense. Because Congress defined the federal crime as participation in a single illegal gambling business, the Court found Sanabria’s acquittal resolved a factual element of that one offense and prevented a second trial on the numbers theory. The Court reversed the First Circuit and denied the Government’s appeal.
Real world impact
The decision protects criminal defendants from being tried twice for a single statutorily defined offense when a trial ends in acquittal. It also narrows the situations in which prosecutors can use appeals to undo midtrial rulings that resulted in acquittal. Prosecutors must choose charging and trial strategies carefully to avoid forfeiting constitutional protections.
Dissents or concurrances
Justice Stevens joined the opinion but disagreed with a footnote suggesting partial-count appeals; Justice Blackmun, joined by Justice Rehnquist, dissented and would have allowed review under a different earlier case.
Opinions in this case:
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