Ex Parte James Beauford Lamb, Jr. (in Re James Beauford Lamb, Jr. v. State of Alabama)

Summary

The court held that a trial court may not recall a jury after discharge and outside the court's control to resolve a conflict between an oral verdict and a written verdict. Because the written verdict finding Lamb not guilty on count II became final when the jury was discharged, changing it to guilty violated double-jeopardy protections. The court reversed the Court of Criminal Appeals' judgment and remanded for further proceedings. Justice Shaw, dissenting, would have affirmed because the jury's pre-discharge polling confirmed that its verdict on count II was guilty.