STATE OF MARYLAND v. MICHAEL M. JOHNSON
Court of Special Appeals, Wright, June 29, 2016,
Jurisdiction – A court has no jurisdiction to rule on a motion made in a criminal proceeding where a mistrial was granted and jury discharged

(Dissent – Friedman – any acquittal should bar retrial so long as there is personal and subject-matter jurisdiction)

Mistrial – In a jury trial, a mistrial may not be reconsidered after the jury is discharged (“revisory power over the grant of a mistrial… if it exists at all, exists only until the jury is discharged”)

Nunc Pro Tunc – The purpose of the “nunc pro tunc” doctrine is to correct a clerical error or omission, not a judicial error