MICHAEL M. JOHNSON v. STATE OF MARYLAND
Court of Appeals, Battaglia, April 26, 2017,
Double Jeopardy- A trial court does not have authority to grant an acquittal after he has declared a mistrial and discharged the jury weeks earlier

The Court probably should have overruled Taylor et al instead of just differentiating

Grant of a judgment of acquittal outside of Rule 4-324 “is not a mere procedural irregularity but a dispossession of authority.”

The acquittal was granted, thus, not in the context of a “mere procedural irregularity” but in the circumstance in which the judge was totally without authority to act.

Differentiates between “mere procedural irregularity” and situations where “the judge was totally without authority to act.”