Santana v. State

Summary

The Court affirmed the denial of Miguel Angel Santana’s motion to dismiss a third prosecution after his second trial ended in a defense-requested mistrial. Assuming without deciding that Maryland common law bars retrial when the State recklessly causes such a mistrial, the Court held that the circuit court’s finding that the State was not reckless was not clearly erroneous. The Court therefore affirmed the Appellate Court’s judgment and Santana’s convictions.