Martinez v. Illinois
United States Supreme Court
134 S. Ct. 2070 (2014)
- Written by Alex Ruskell, JD
Facts
Esteban Martinez (defendant) was indicted in Illinois state court for aggravated battery and mob action against Avery Binion and Demarco Scott. A court date was finally set after several continuances due to the state’s inability to find Binion and Scott, who were slated to act as witnesses. At trial, the prosecutor asked the court for another continuance because the state could still not find Binion and Scott. The judge denied the continuance and swore in a jury to start the proceedings. The prosecutor then told the judge that under the circumstances the state would not participate in the case. Martinez moved for a directed verdict, and the judge found Martinez not guilty on both counts. The state appealed to the Illinois Appellate Court. Martinez argued that the appeal was improper under double jeopardy, but the appeals court reversed the trial court’s decision. The appeals court held that the case was appealable because no jeopardy had attached in the previous trial because no witnesses were sworn in and no evidence was presented. The Illinois Supreme Court affirmed, and Martinez appealed to the United States Supreme Court, which granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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