BRAVO-FERNANDEZ v. UNITED STATES
Supreme Court of the United States, Ginsburg, Nov. 29, 2016,
Double Jeopardy – Issue Preclusion – Inconsistent jury verdicts do not result in issue preclusion when the guilty verdict is vacated for unrelated reasons
(Concur – Thomas – Quoting Scalia’s dissents as to issue preclusion being part of Double Jeopardy at all)
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DOMINIC GIVENS v. STATE OF MARYLAND
Court of Appeals, Watts, August 24, 2016,
Inconsistent Verdicts – To preserve an issue of inconsistent jury verdicts, a defendant must object before the verdicts become final and the trial court discharges the jury.
(Dissent – Greene join by Adkins, Battaglia – Court should review under plain error; judge should be able to send back verdict as illegal)
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OCTAVIUS SAVAGE v. STATE OF MARYLAND
Court of Special Appeals, Raker, Filed Dec. 15, 2015,
Conspiracy – Conviction for conspiracy to commit murder is not legally inconsistent despite conviction on 2nd degree murder and acquittal on first degree murder
(opinion re-issued March 23, 2016)
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