Randall v. Rothwax, 78 N.Y.2d 494 (1991)
When a trial court provides inaccurate information about a jury’s deliberations, inducing a guilty plea that is later vacated, double jeopardy may bar retrial if the defendant was deprived of the right to have their case decided by that specific jury.
Summary
A 17-year-old defendant was tried for attempted murder. After jury deliberations, the trial court erroneously informed the defendant that the jury was leaning towards conviction, when in fact, the opposite was true. Based on this misinformation, the defendant pleaded guilty to a lesser charge, but later successfully moved to withdraw the plea. The defendant then argued that retrial was barred by double jeopardy. The New York Court of Appeals held that retrial was barred because the trial court’s actions deprived the defendant of his right to have his guilt or innocence determined by the original jury.
Facts
The defendant was on trial for attempted murder. After eight hours of deliberation, the jury reported being deadlocked. The trial judge, based on incorrect information from a court officer, told the defendant’s counsel that the jury was leaning 10-2 towards conviction and even identified the jurors supposedly favoring acquittal. This was false; the jury was actually leaning 10-2 towards acquittal. Influenced by this misinformation and fearing a lengthy prison sentence, the defendant pleaded guilty to a lesser charge to avoid the risk of conviction on the higher charge. After the plea was entered and the jury discharged, jurors revealed the actual vote tally was in favor of acquittal.
Procedural History
The defendant moved to withdraw his guilty plea, which the trial court granted. The defendant then moved to preclude retrial, arguing double jeopardy. The trial court denied this motion. The Appellate Division reversed, granting prohibition against further criminal proceedings. The New York Court of Appeals affirmed the Appellate Division’s judgment.
Issue(s)
Whether the Double Jeopardy Clause bars retrial of a defendant after the defendant’s guilty plea, induced by the trial court’s incorrect information about the jury’s deliberations, is vacated.
Holding
Yes, because the trial court’s actions deprived the defendant of the fundamental right to have his case decided by the original jury, and vacating the guilty plea could not restore this right.
Court’s Reasoning
The Court of Appeals reasoned that the defendant was constitutionally entitled to the original jury’s resolution of his guilt or innocence. The court’s inaccurate communication regarding the jury’s tentative vote, bolstered by the court’s authority, effectively coerced the defendant into pleading guilty. The court emphasized that the plea offer, delivered with incorrect data about the tentative vote of the deliberating jury, was “an offer that defendant could not seriously refuse.” The defendant was thus deprived of the freedom of will necessary for a knowing and voluntary plea. The court distinguished this case from United States v. Tateo, where retrial was permitted after a coerced guilty plea was vacated, because in this case, the trial court’s actions eliminated the defendant’s fundamental right to have his trial completed by that particular tribunal. The court stated that “the crucial difference between reprosecution after appeal by the defendant and reprosecution after a sua sponte judicial mistrial declaration is that in the first situation the defendant has not been deprived of [the] option to go to the first jury…” Here, the defendant was deprived of that option. The court also expressed concern about the integrity of jury deliberations, stating that the information imparted by the trial justice gave the erroneous impression that the confidentiality of the deliberations had been officially penetrated. As the court noted, “[t]he vacatur of a guilty plea in this circumstance is not at all similar to other typical relief sought by and granted to defendants from trial or appellate courts, which permit further proceedings on an indictment.”