Bravo-Fernandez v. United States | |
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Argued October 4, 2016 Decided November 29, 2016 | |
Full case name | Juan Bravo-Fernandez and Hector Martinez-Maldonado, Petitioners v. United States |
Docket no. | 15-537 |
Citations | 580 U.S. ___ ( more ) 137 S. Ct. 352; 196 L. Ed. 2d 242 |
Case history | |
Prior | United States v. Bravo-Fernandez, 790 F.3d 41 (1st Cir. 2015); cert. granted, 136 S. Ct. 1491 (2016). |
Holding | |
The issue-preclusion component of the Double Jeopardy Clause does not bar the Government from retrying defendants, like petitioners, after a jury has returned irreconcilably inconsistent verdicts of conviction and acquittal and the convictions are later vacated for legal error unrelated to the inconsistency. | |
Court membership | |
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Case opinions | |
Majority | Ginsburg, joined by unanimous |
Concurrence | Thomas |
Laws applied | |
U.S. Const. amend. V |
Bravo-Fernandez v. United States, 580 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified the application of the Fifth Amendment's Double Jeopardy Clause to cases in which a jury returns irreconcilable verdicts that convict a defendant on one count and acquit a defendant on another count when both counts rely upon the same ultimate fact. [1]
In a unanimous opinion written by Justice Ruth Bader Ginsburg, the Court held that the government may re-try criminal defendants after a jury returns irreconcilable verdicts when the conviction is later vacated because of a procedural error that is unrelated to the inconsistency. [2] Justice Clarence Thomas filed a concurring opinion, stating that although he joins with the majority, the Court should reconsider the two cases that Ginsburg relied on in her argument, Ashe v. Swenson and Yeager v. United States . [3]
Apodaca v. Oregon, 406 U.S. 404 (1972), was a United States Supreme Court case in which the Court held that state juries may convict a defendant by a less-than-unanimous verdict in a felony criminal case. The four-justice plurality opinion of the court, written by Justice White, affirmed the judgment of the Oregon Court of Appeals and held that there was no constitutional right to a unanimous verdict. Although federal law requires federal juries to reach criminal verdicts unanimously, the Court held Oregon's practice did not violate the Sixth Amendment right to trial by jury and so allowed it to continue. In Johnson v. Louisiana, a case decided on the same day, the Court held that Louisiana's similar practice of allowing criminal convictions by a jury vote of 9–3 did not violate due process or equal protection under the Fourteenth Amendment.
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Spokeo, Inc. v. Robins, 578 U.S. 330 (2016), was a United States Supreme Court case in which the Court vacated and remanded a ruling by United States Court of Appeals for the Ninth Circuit on the basis that the Ninth Circuit had not properly determined whether the plaintiff has suffered an "injury-in-fact" when analyzing whether he had standing to bring his case in federal court. The Court did not discuss whether "the Ninth Circuit’s ultimate conclusion — that Robins adequately alleged an injury in fact — was correct."
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Romag Fasteners, Inc. v. Fossil, Inc., 590 U.S. ___ (2020), was a United States Supreme Court case related to trademark law under the Lanham Act. In the 9–0 decision on judgement, the Court ruled that a plaintiff in a trademark infringement lawsuit is not required to demonstrate that the defendant willfully infringed on their trademark to claim lost profit damages.
Ruan v. United States, 597 U.S. ___ (2022), was a case decided by the Supreme Court of the United States.