WILLIE QUINONES v. STATE OF MARYLAND
Court of Special Appeals, Bair, Filed Nov. 5, 2013,
Mistrial- When co-defendant’s charges were nolle prossed before closing argument, jury was instructed to draw no inferences from this, and defense counsel instructed not to invite such inferences; it was not abuse of discretion for trial court to declare a mistrial over defense objection when defense counsel did so repeatedly.

Other notes from the case:
– Once jeopardy attaches, the State is prohibited from retrying the accused if the trial court declares a mistrial over defendant’s objection “unless there is a showing of manifest necessity to declare the mistrial.”
– In order to determine manifest necessity to declare a mistrial, the trial judge must weigh the unique facts and circumstances of each case, explore reasonable alternatives, and determine that no reasonable alternative exists.