Holland v. State

Summary

The Court held that Delaware's statutory bar on successive prosecutions did not prevent the State from charging Holland with attempted robbery after the first jury acquitted him of assault charges but deadlocked on other counts. The Court also rejected Holland's collateral-estoppel argument and upheld the finding that he knowingly, intelligently, and voluntarily waived his right to counsel. It nevertheless held that the State failed to rebut the presumption of vindictive prosecution arising from bringing the new, similarly weighty charges after the first trial, and therefore reversed the convictions on those new charges and related counts while leaving the remaining convictions intact.