Blueford v. Arkansas

566 U.S. 599 (2012)

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Nature of the Case

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Facts

One-year-old Matthew suffered a severe head injury while home with his mother's boyfriend, D. He died a few days later. P charged D with capital murder but waived the death penalty. P claimed that D had injured Matthew intentionally, causing the boy's death “under circumstances manifesting extreme indifference to the value of human life.” D claimed that he accidentally knocked Matthew onto the ground. The court instructed the jury that capital murder included three lesser offenses: first-degree murder, manslaughter, and negligent homicide. The court described these offenses and addressed the order in which the jury was to consider them. “If you have a reasonable doubt of the defendant's guilt on the charge of capital murder, you will consider the charge of murder in the first degree. . . . If you have a reasonable doubt of the defendant's guilt on the charge of murder in the first degree, you will then consider the charge of manslaughter. . . . If you have a reasonable doubt of the defendant's guilt on the charge of manslaughter, you will then consider the charge of negligent homicide.” P told them “before you can consider a lesser included of capital murder, you must first, all 12, vote that this man is not guilty of capital murder.” The charges were to be taken up serially. The jury got 4 verdict forms for guilt and one for acquittal. The jury could not agree and was instructed again by the court and still could not agree. It had found D not guilty of capital murder and first-degree murder but was stuck on manslaughter (9-3 against) and had not taken up negligent homicide. The court instructed them again and D asked for an acquittal on the first two charges. The court refused. Again they returned with the same results and the court declared a mistrial. D moved to dismiss the capital and first-degree murder charges on double jeopardy grounds. The motion was denied. The court of appeals and state supreme court affirmed. It held that no formal verdict had been issued. The Supreme Court granted certiorari.