mistrial claim (Virginia) · Go Syfert
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mistrial claim in Virginia

8 Virginia opinions name it 2 courts 1997–2011 0 in the last five years

The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Bennett v. Commonwealthgreen
vactapp · 1999 · cited in 3 Virginia opinions naming this issue, 2009–2009
2 sentences

2009See, e.g., Bennett v. Commonwealth, 29 Va.App. 261, 280 , 511 S.E.2d 439, 448 (1999); see also Manetta v. Commonwealth, 231 Va. 123 , 127 n. 2, 340 S.E.2d 828 , 830 n. 2 (1986) (recognizing the well-settled principle that, where a defendant successfully objects to the admission of evidence and requests that it be stricken or obtains a ruling that evidence is admissible for only a limited purpose, a court has no duty to give a cautionary or limiting instruction unless the defendant specifically requests one).

2009See, e.g., Bennett v. Commonwealth, 29 Va.App. 261, 280 , 511 S.E.2d 439, 448 (1999); see also Manetta v. Commonwealth, 231 Va. 123 , 127 n. 2, 340 S.E.2d 828 , 830 n. 2 (1986) (recognizing the well-settled principle that, where a defendant successfully objects to the admission of evidence and requests that it be stricken or obtains a ruling that evidence is admissible for only a limited purpose, a court has no duty to give a cautionary or limiting instruction unless the defendant specifically requests one).

33
Manetta v. Commonwealthgreen
va · 1986 · cited in 3 Virginia opinions naming this issue, 2009–2009
2 sentences

2009See, e.g., Bennett v. Commonwealth, 29 Va.App. 261, 280 , 511 S.E.2d 439, 448 (1999); see also Manetta v. Commonwealth, 231 Va. 123 , 127 n. 2, 340 S.E.2d 828 , 830 n. 2 (1986) (recognizing the well-settled principle that, where a defendant successfully objects to the admission of evidence and requests that it be stricken or obtains a ruling that evidence is admissible for only a limited purpose, a court has no duty to give a cautionary or limiting instruction unless the defendant specifically requests one).

2009See, e.g., Bennett v. Commonwealth, 29 Va.App. 261, 280 , 511 S.E.2d 439, 448 (1999); see also Manetta v. Commonwealth, 231 Va. 123 , 127 n. 2, 340 S.E.2d 828 , 830 n. 2 (1986) (recognizing the well-settled principle that, where a defendant successfully objects to the admission of evidence and requests that it be stricken or obtains a ruling that evidence is admissible for only a limited purpose, a court has no duty to give a cautionary or limiting instruction unless the defendant specifically requests one).

33
United States v. Cheryl Lynne Puleogreen
ca11 · 1987 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008Not only “may [a criminal defendant] waive his” double jeopardy rights in the mistrial context, “[t]his waiver may be express or implied.” Mack v. Commonwealth, 177 Va. 921, 929 , 15 S.E.2d 62, 65 (1941); see also Puleo, 817 F.2d at 705 (“[W]here the trial judge expressed a clear intent to declare a mistrial and the defense counsel had an opportunity to object but did not” the appellant “consented to the mistrial” and noting, “[i]t has certainly never been the rule that consent need be express; indeed, consent may always be ‘implied from the totality of circumstances attendant on the declarati

2008Commonwealth v. Washington, 3 This standard has also been codified in Virginia: “the court may, in its discretion . . . discharge the jury when it appears that . . . there is manifest necessity for such discharge.” Code § 8.01-361. -6- 263 Va. 298, 304-05 , 559 S.E.2d 636, 639 (2002) 4 ; see also Puleo, 817 F.2d at 705 ; Goldstein, 479 F.2d at 1067 .

11
Mack v. Commonwealthgreen
· 1941 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008Not only “may [a criminal defendant] waive his” double jeopardy rights in the mistrial context, “[t]his waiver may be express or implied.” Mack v. Commonwealth, 177 Va. 921, 929 , 15 S.E.2d 62, 65 (1941); see also Puleo, 817 F.2d at 705 (“[W]here the trial judge expressed a clear intent to declare a mistrial and the defense counsel had an opportunity to object but did not” the appellant “consented to the mistrial” and noting, “[i]t has certainly never been the rule that consent need be express; indeed, consent may always be ‘implied from the totality of circumstances attendant on the declarati

2008Not only “may [a criminal defendant] waive his” double jeopardy rights in the mistrial context, “[t]his waiver may be express or implied.” Mack v. Commonwealth, 177 Va. 921, 929 , 15 S.E.2d 62, 65 (1941); see also Puleo, 817 F.2d at 705 (“[W]here the trial judge expressed a clear intent to declare a mistrial and the defense counsel had an opportunity to object but did not” the appellant “consented to the mistrial” and noting, “[i]t has certainly never been the rule that consent need be express; indeed, consent may always be ‘implied from the totality of circumstances attendant on the declarati

11
Commonwealth v. Washingtongreen
va · 2002 · cited in 1 Virginia opinions naming this issue, 2008–2008
2 sentences

2008Commonwealth v. Washington, 3 This standard has also been codified in Virginia: “the court may, in its discretion . . . discharge the jury when it appears that . . . there is manifest necessity for such discharge.” Code § 8.01-361. -6- 263 Va. 298, 304-05 , 559 S.E.2d 636, 639 (2002) 4 ; see also Puleo, 817 F.2d at 705 ; Goldstein, 479 F.2d at 1067 .

2008Commonwealth v. Washington, 3 This standard has also been codified in Virginia: “the court may, in its discretion . . . discharge the jury when it appears that . . . there is manifest necessity for such discharge.” Code § 8.01-361. -6- 263 Va. 298, 304-05 , 559 S.E.2d 636, 639 (2002) 4 ; see also Puleo, 817 F.2d at 705 ; Goldstein, 479 F.2d at 1067 .

11
United States v. Perezgreen
scotus · 1824 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002United States v. Perez, 22 U.S. 579, 580 (1824); see also Allen, 252 Va. at 109 , 472 S.E.2d at 279 .

2002United States v. Perez, 22 U.S. (9 Wheat.) 579, 580 , 6 L.Ed. 165 (1824); see also Allen, 252 Va. at 109 , 472 S.E.2d at 279 .

11
Allen v. Commonwealthgreen
va · 1996 · cited in 1 Virginia opinions naming this issue, 2002–2002
2 sentences

2002United States v. Perez, 22 U.S. 579, 580 (1824); see also Allen, 252 Va. at 109 , 472 S.E.2d at 279 .

2002United States v. Perez, 22 U.S. 579, 580 (1824); see also Allen, 252 Va. at 109 , 472 S.E.2d at 279 .

11
MacKenzie v. Commonwealthgreen
vactapp · 1989 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997Id. at 553, 439 S.E.2d at 623 (citing MacKenzie v. Commonwealth, 8 Va.App. 236, 240 , 380 S.E.2d 173, 175 (1989)).

1997Id. at 553, 439 S.E.2d at 623 (citing MacKenzie v. Commonwealth, 8 Va.App. 236, 240 , 380 S.E.2d 173, 175 (1989)).

11
Robinson v. Commonwealthgreen
vactapp · 1994 · cited in 1 Virginia opinions naming this issue, 1997–1997
2 sentences

1997A. In Robinson v. Commonwealth, 17 Va.App. 551, 553 , 439 S.E.2d 622, 623 , aff'd en banc, 18 Va.App. 814 , 447 S.E.2d 542 (1994), we held that prosecutorial misconduct causing a mistrial does not bar retrial unless the prosecutor intended to subvert the protection afforded by the Double Jeopardy Clause.

1997A. In Robinson v. Commonwealth, 17 Va.App. 551, 553 , 439 S.E.2d 622, 623 , aff'd en banc, 18 Va.App. 814 , 447 S.E.2d 542 (1994), we held that prosecutorial misconduct causing a mistrial does not bar retrial unless the prosecutor intended to subvert the protection afforded by the Double Jeopardy Clause.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Remmer v. United States green
scotus · 1954
1 sentence

2011Id. at 228-29 .

12011–2011
Lewis v. Com. green
va · 2005
2 sentences

2011Id. at 212 , 608 S.E.2d at 909 .

2011Id. at 212 , 608 S.E.2d at 909 .

12011–2011
United States v. Albert Goldstein green
ca2 · 1973
2 sentences

2008Not only “may [a criminal defendant] waive his” double jeopardy rights in the mistrial context, “[t]his waiver may be express or implied.” Mack v. Commonwealth, 177 Va. 921, 929 , 15 S.E.2d 62, 65 (1941); see also Puleo, 817 F.2d at 705 (“[W]here the trial judge expressed a clear intent to declare a mistrial and the defense counsel had an opportunity to object but did not” the appellant “consented to the mistrial” and noting, “[i]t has certainly never been the rule that consent need be express; indeed, consent may always be ‘implied from the totality of circumstances attendant on the declarati

2008Commonwealth v. Washington, 3 This standard has also been codified in Virginia: “the court may, in its discretion . . . discharge the jury when it appears that . . . there is manifest necessity for such discharge.” Code § 8.01-361. -6- 263 Va. 298, 304-05 , 559 S.E.2d 636, 639 (2002) 4 ; see also Puleo, 817 F.2d at 705 ; Goldstein, 479 F.2d at 1067 .

12008–2008
Robinson v. Commonwealth green
vactapp · 1994
1 sentence

1997A. In Robinson v. Commonwealth, 17 Va.App. 551, 553 , 439 S.E.2d 622, 623 , aff'd en banc, 18 Va.App. 814 , 447 S.E.2d 542 (1994), we held that prosecutorial misconduct causing a mistrial does not bar retrial unless the prosecutor intended to subvert the protection afforded by the Double Jeopardy Clause.

11997–1997
Robinson v. Com. green
vactapp · 1994
2 sentences

1997A. In Robinson v. Commonwealth, 17 Va.App. 551, 553 , 439 S.E.2d 622, 623 , aff'd en banc, 18 Va.App. 814 , 447 S.E.2d 542 (1994), we held that prosecutorial misconduct causing a mistrial does not bar retrial unless the prosecutor intended to subvert the protection afforded by the Double Jeopardy Clause.

1997Id. at 553, 439 S.E.2d at 623 (citing MacKenzie v. Commonwealth, 8 Va.App. 236, 240 , 380 S.E.2d 173, 175 (1989)).

11997–1997

Statutes the citing opinions construe

VA § Va. Code Ann. § 8.01-384 (4) VA § Va. Code Ann. § 17.1-400 (3) VA § Va. Code Ann. § 17.1-413 (3) VA § Va. Code Ann. § 18.2-456 (3) VA § Va. Code Ann. § 19.2-318 (3) VA § Va. Code Ann. § 19.2-319 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 139 (1949–2025) GA 73 (1928–2024) LA 22 (1976–2023) PA 20 (1971–2021) CA 20 (1970–2025) IL 15 (1975–2026) AR 15 (1975–2025) MI 15 (1975–2026) OH 15 (1993–2025) FL 14 (1972–2024) MO 13 (1972–2018) AZ 12 (1968–2025) IN 12 (1979–2020) NJ 11 (1973–2021) NY 9 (1972–2020) VA 8 (1997–2011) OR 7 (1963–2023) OK 7 (1977–2024) AL 7 (1983–2024) RI 6 (1992–2001) UT 6 (1992–2025) DC 6 (1977–2024) WI 6 (1979–2024) NM 6 (1967–2024) CT 5 (1986–2025) SD 5 (2019–2023) MS 5 (1990–2014) NH 5 (1988–2014) MA 5 (1974–2025) NE 5 (1963–1983) NC 4 (1977–2012) WA 4 (2008–2019) KS 4 (1978–2021) WY 4 (1989–2025) HI 3 (2002–2020) MN 3 (1989–2016) SC 3 (2011–2018) TN 3 (1983–2011) CO 3 (2016–2016) AK 3 (1981–2011) DE 2 (2019–2019) KY 2 (2016–2018) ND 2 (1982–1988) IA 2 (2020–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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