Smith v. United States

Summary

The Supreme Court held that a conviction reversed because the trial was held in an improper venue and before a jury drawn from the wrong district does not bar a retrial under the Double Jeopardy Clause. The Court affirmed the Eleventh Circuit's decision vacating the conviction and allowing a new trial. The decision rests on the longstanding retrial rule and the view that venue and vicinage violations are remedied by a new trial, not by barring reprosecution.