United States v. Martin Linen Supply Co. et al.
430 U.S. 564 (1977)
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Rule of Law:
The Double Jeopardy Clause of the Fifth Amendment bars the government from appealing a district court's judgment of acquittal, entered under Federal Rule of Criminal Procedure 29(c) after a jury deadlocks, because a successful appeal would necessitate a second trial or further proceedings on the merits of the case.
Facts:
- The United States initiated a criminal contempt proceeding against two commonly owned linen supply companies, Martin Linen Supply Co. and another, and their president, William B. Troy.
- The proceeding alleged that the defendants had violated a consent decree that had been entered as the final judgment in an antitrust suit.
- The case proceeded to a jury trial.
- At the conclusion of the trial, the jury returned a verdict of 'not guilty' for the company president, William B. Troy.
- The jury announced that it was 'hopelessly deadlocked' regarding the guilt of the two corporations.
Procedural Posture:
- The United States brought a criminal contempt action against Martin Linen Supply Co. and another corporation in the U.S. District Court for the Western District of Texas.
- Following a trial, the jury deadlocked as to the corporations' guilt, and the District Court declared a mistrial and discharged the jury.
- The corporations then filed timely motions for judgments of acquittal pursuant to Federal Rule of Criminal Procedure 29(c).
- The District Court granted the motions and entered judgments of acquittal.
- The United States, as appellant, appealed the acquittals to the U.S. Court of Appeals for the Fifth Circuit.
- The Court of Appeals held that the Double Jeopardy Clause barred the appeal and dismissed it for lack of jurisdiction.
- The United States petitioned the Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does the Double Jeopardy Clause bar the United States from appealing a judgment of acquittal entered by a district court under Federal Rule of Criminal Procedure 29(c) after the jury was discharged because it was hopelessly deadlocked?
Opinions:
Majority - Mr. Justice Brennan
No. The Double Jeopardy Clause bars the government from appealing this judgment of acquittal. A core principle of double jeopardy jurisprudence is that a verdict of acquittal is final and cannot be reviewed without putting a defendant twice in jeopardy. What constitutes an 'acquittal' is a matter of substance, not form, and depends on whether the judge's ruling represents a resolution on the merits of the factual elements of the offense. In this case, the district court evaluated the government's evidence and explicitly found it was legally insufficient to sustain a conviction. This ruling was an acquittal in substance. A successful government appeal would require a new trial or further proceedings to resolve factual issues, which is precisely what the Double Jeopardy Clause prohibits. The timing of the acquittal under Rule 29—whether before the case goes to the jury or after a mistrial—is irrelevant to its constitutional finality.
Concurring - Mr. Justice Stevens
No. The appeal is barred by statute, not necessarily the Constitution. The plain language and legislative history of the Criminal Appeals Act, 18 U.S.C. § 3731, demonstrate that Congress only authorized government appeals from dismissals of an indictment, not from judgments of acquittal. The legislative history explicitly states the purpose was to resolve issues with appeals from dismissals, 'other than by judgments of acquittal.' Since the district court's ruling was clearly an acquittal in both substance and form, there is no statutory authority for the government's appeal, and the constitutional question need not be reached.
Dissenting - Mr. Chief Justice Burger
Yes. The Double Jeopardy Clause does not bar the appeal. Once the jury was discharged due to a deadlock, the jeopardy of the first trial terminated, and the defendants were already subject to reprosecution. The district judge's subsequent ruling on the Rule 29(c) motion was a determination on the legal sufficiency of the evidence—a question of law, not fact—made at a time when the defendants were no longer in jeopardy from the first trial. This situation is constitutionally indistinguishable from United States v. Sanford, where a post-mistrial dismissal was held to be appealable. By focusing on the 'acquittal' label, the majority elevates form over substance and bars the government from seeking appellate review of a purely legal ruling.
Analysis:
This decision solidifies the finality of a judicial acquittal, establishing that a judge's ruling on the insufficiency of evidence carries the same double jeopardy weight as a jury's verdict of not guilty. It clarifies that Rule 29(c), which allows a judge to acquit after a jury deadlocks, is not a loophole for government appeals. By treating such acquittals as absolute, the Court reinforces the principle that the Double Jeopardy Clause protects a defendant from the ordeal of a second trial after a determination has been made on the merits, regardless of whether that determination was made by a judge or jury.
