State of Connecticut v. Richard Anderson; State of Connecticut v. Janice Anderson

Summary

The court held that the trial court did not abuse its discretion by declaring a mistrial over the defendants’ objection after the prosecuting attorney became seriously ill and could not continue. The circumstances, including the prosecutor’s indefinite unavailability, the complexity of the case, the lack of a feasible substitute prosecutor, and juror scheduling concerns, established manifest necessity, so retrial was not barred by double jeopardy. Justice Katz, dissenting, would have concluded that the record did not adequately establish that a continuance with substitute counsel was infeasible.