Matter of Enright v. People, 58 N.Y.2d 172 (1983)
A mistrial may be declared without the defendant’s consent only when there is a “manifest necessity” to protect the defendant’s right to a fair trial or when the ends of public justice would be defeated.
Summary
This case addresses the circumstances under which a trial court may declare a mistrial without the defendant’s consent, thereby permitting a retrial without violating double jeopardy protections. The New York Court of Appeals held that a mistrial was justified in two separate cases: In Enright, the prosecution inadvertently introduced a suppressed confession. In Huntzinger, a key defense witness became unavailable and defense counsel made prejudicial remarks during voir dire. The Court emphasized that a trial judge’s determination of manifest necessity warrants deference due to their superior position to assess the situation, but the reasons for mistrial must be “necessitous, actual and substantial.”
Facts
Enright: Defendant was indicted for robbery. After a Huntley hearing, his confession was initially deemed admissible. The confession was referenced in opening statements. The prosecutor then discovered a Miranda rights statement indicating Enright requested counsel before confessing. The confession was suppressed.
Huntzinger: Defendant was indicted for sodomy. He appeared at trial in a wheelchair, accompanied by an attendant. During voir dire, defense counsel made statements appealing to the jury’s sympathy. After the jury was sworn, the trial court declared a mistrial because of: 1) prejudice to the People from the defendant’s appearance; 2) improper remarks during voir dire; and 3) the unavailability of a crucial defense witness (Chief Jackson), who could not testify due to surgery.
Procedural History
Enright: After the trial court declared a mistrial, Enright sought to prohibit retrial via an Article 78 proceeding. The Appellate Division held the mistrial was an abuse of discretion.
Huntzinger: After the trial court declared a mistrial, Huntzinger commenced an Article 78 proceeding seeking to prohibit retrial. The Appellate Division held that the mistrial was an abuse of discretion.
The Court of Appeals consolidated the appeals of both cases.
Issue(s)
1. Whether the trial court abused its discretion in declaring a mistrial in Enright after the prosecution inadvertently referenced a suppressed confession in its opening statement.
2. Whether the trial court abused its discretion in declaring a mistrial in Huntzinger due to the defendant’s sympathetic appearance, defense counsel’s improper voir dire statements, and the unavailability of a key defense witness.
Holding
1. No, because there was “manifest necessity” to declare a mistrial to ensure a fair trial for the defendant after a confession was presented to the jury and later suppressed.
2. No, because considering the combination of the defendant’s appearance, the improper voir dire remarks, and the unavailability of a crucial witness, the trial court did not abuse its discretion.
Court’s Reasoning
The Court of Appeals stated that retrial is barred after a mistrial declared without defendant’s consent unless there is “manifest necessity” for the mistrial or the ends of public justice would be defeated. The Court emphasized deference to the trial judge’s discretion, recognizing that the trial judge is in the best position to determine necessity. However, the reasons for the mistrial must be “necessitous, actual and substantial” and not merely for the convenience of the court. The court noted, ” ‘a defendant’s valued right to have his trial completed by a particular tribunal must in some circumstances be subordinated to the public’s interest in fair trials designed to end in just judgments.’ ”
In Enright, the court found the inadvertent introduction of the suppressed confession created prejudice for both sides, as unsophisticated jurors may struggle to disregard the confession. The court emphasized that Enright’s counsel agreed the jury could not be “sanitized.” Therefore, the mistrial was justified to protect the defendant’s right to a fair trial.
In Huntzinger, the court found the unavailability of Chief Jackson, deemed “absolutely crucial” by the defense, justified the mistrial. The defense could not estimate the length of Jackson’s unavailability, so the trial judge was not obligated to grant an indefinite continuance. The Court found that considering the witness unavailability along with the improper remarks during voir dire supported the mistrial declaration.
The court concluded by stating that in both cases, the trial judge did not abuse their discretion, reversing the judgment of the Appellate Division and dismissing the petitions.