Supreme Court of the United States
Juan Bravo-Fernandez and Hector Martínez-Maldonado v. United States.
November 29, 2016137 S. Ct. 352
Summary
The Supreme Court held that the Double Jeopardy Clause's issue-preclusion component does not bar retrial when a jury returns inconsistent verdicts of conviction and acquittal, even if the convictions are later vacated for unrelated legal error. The Court distinguished Yeager v. United States (hung counts) from United States v. Powell (inconsistent verdicts), reasoning that vacated convictions remain jury decisions that render the acquittal's preclusive effect unanswerable. Justice Thomas concurred, suggesting Ashe and Yeager should be reconsidered in an appropriate case.