From Casetext: Smarter Legal Research

United States v. Ingram

United States District Court, D. Columbia
Jan 7, 1976
412 F. Supp. 384 (D.D.C. 1976)

Summary

In Ingram, the district court dismissed the indictment sua sponte (without any initial objection by the Government) after two mistrials—in which jurors had voted 10-2 and 11-1 for acquittal, the defendant was jailed during the pendency of the trials, and "[t]he Government ha[d] no new proof; it simply want[ed] another chance."

Summary of this case from United States v. Wright

Opinion

Crim. No. 75-443.

January 7, 1976.

Edward C. McGuire, Asst. U.S. Atty., Washington, D.C., for U.S.

Michael A. Kramer, Washington, D.C., for defendant.


MEMORANDUM AND ORDER


Defendant, while on parole from a sentence for armed robbery under the Federal Youth Corrections Act, 18 U.S.C. § 5010(c), was arrested on May 16, 1975, for the bank robbery charged in the instant indictment. He has remained in jail since that date because of a parole violation warrant based on the new offense and other deficiencies and for failing to make bond in the instant case. Twice now he has gone to trial. Defendant did not testify at either trial and presented no proof contradicting the Government witnesses except by way of effective cross-examination. The proof was legally sufficient to support a conviction in each instance but the juries simply did not credit the witnesses, voting 10-2 and 11-1 for acquittal. After the second mistrial, the Court dismissed the indictment sua sponte from the bench without any objection then being voiced by the United States. Almost a month later the prosecution has moved for reconsideration, questioning the Court's power under the circumstances.

Thus, once again the ever recurring problem is presented whether any discretion exists in a United States District Judge to terminate a useless prosecution. This is, of course, not a case of double jeopardy. See Illinois v. Somerville, 410 U.S. 458, 463, 470, 93 S.Ct. 1066, 1070, 1073, 35 L.Ed.2d 425, 430, 434 (1973). It is simply a matter of fair play. The Government has no new proof; it simply wants another chance. Despite its contentions, the prosecution was not prejudiced by defense counsel's reference to the obvious fact that defendant is black and the identifying witness a white. There were aspects in addition to race that weakened her in-court identification. Apparently the Government, always a hard loser, simply wishes to keep pressing so long as juries disagree in the hope that a conviction eventually will result. Appellate courts have approved this process of attrition under different circumstances. See United States v. Castellanos, 478 F.2d 749 (2d Cir. 1973); United States v. Weinstein, 452 F.2d 704 (2d Cir. 1971), cert. denied sub nom. Grunberger v. United States, 406 U.S. 917, 92 S.Ct. 1766, 32 L.Ed.2d 116 (1972); United States v. Dooling, 406 F.2d 192 (2d Cir.), cert. denied sub nom. Persico v. United States, 395 U.S. 911, 89 S.Ct. 1744, 23 L.Ed.2d 224 (1969).

Here is a man in jail now more than seven months primarily because of an offense which the Government is unable to convince a jury he committed. If another trial takes place there is every reason to believe the jury will again be divided or will acquit. There is great deference shown jury determinations that result in conviction, and the same attitude should prevail when, as here, members of a jury disagree so conclusively when not even faced with conflicts in the proof. Under the circumstances of this case the verdicts themselves indicate a reasonable doubt in the minds of a substantial majority of the jury members who have heard the evidence. To permit a retrial, after 21 of 24 jurors have already refused to convict, is to ignore the reasonable doubt standard. The Court in dismissing simply recognized the juries' appraisals of the weight of the evidence. The judgment of the Court or the prosecutor as to the weight of the evidence is, under these circumstances, not entitled to outbalance the obvious.

There are also other considerations bearing on the exercise of the Court's power in this situation. Prosecutorial discretion in choosing to indict and to proceed twice has been vindicated. The Court's intervention is required in the interests of justice. See United States v. De Diego, 167 U.S.App.D.C. 252, 511 F.2d 818, 824 n. 8 (1975); id. at 833 n. 6 (McGowan, J., dissenting). Retrials are almost always unsatisfactory. Counsel tend to try them more perfunctorily, testimony lacks freshness, subtle differences in recollections are blown up to challenge credibility and a certain atmosphere of staleness is created. All this impedes the search for truth. We also tend to forget the earnest members of the public who as innocent bystanders have their lives repeatedly disrupted because they were at or near the scene of the offense. Grand jury appearances, line-up appearances, witness interviews by police and prosecutors, suppression motions, trial appearances, all are present here. When does a citizen's obligation cease? The lead Government witness in this case had to make considerable sacrifice to appear at the last trial. Is the Government's inability to convince so paramount that all other considerations become subordinate — the strain on defendant, the burden on inadequately compensated defense counsel, the inconvenience to the bank and its personnel, and the urgency of the more significant court business subject to priority demands? The Court submits that under the situation presented here these factors are proper additional elements to be taken into account.

The motion for reconsideration is denied.

SO ORDERED.


Summaries of

United States v. Ingram

United States District Court, D. Columbia
Jan 7, 1976
412 F. Supp. 384 (D.D.C. 1976)

In Ingram, the district court dismissed the indictment sua sponte (without any initial objection by the Government) after two mistrials—in which jurors had voted 10-2 and 11-1 for acquittal, the defendant was jailed during the pendency of the trials, and "[t]he Government ha[d] no new proof; it simply want[ed] another chance."

Summary of this case from United States v. Wright

In United States v. Ingram, 412 F. Supp. 384 (D.D.C. 1976), the court dismissed the indictment after the defendant was tried twice for bank robbery.

Summary of this case from United States v. Wright

dismissing an indictment with prejudice after two trials resulted in hung juries because it was "simply a matter of fair play"

Summary of this case from United States v. Khan

In Ingram, supra, the court held that dismissal of an indictment after the defendant's second mistrial was required in the "interests of justice" as "simply a matter of fair play."

Summary of this case from People v. Sierb

disallowing reprosecution of defendant following two hung juries in which twenty-one out of twenty-four jurors voted for acquittal

Summary of this case from State v. Sauve

In United States v. Ingram,412 F. Supp. 384 (D.D.C. 1976), for example, the court dismissed the indictment after the defendant was tried twice for armed robbery, and the juries voted 10-2 and 11-1 for acquittal, respectively.

Summary of this case from State v. Abbati

In Ingram, the trial judge dismissed the case from the bench after two trials resulted in jury votes of ten-to-two and eleven-to-one for acquittal. That case can be distinguished from the present case for two reasons.

Summary of this case from Ex Parte Anderson

considering dismissal a "matter of fair play"

Summary of this case from State v. Gonzales

In Ingram, the court noted that it was "simply a matter of fair play" and held that "(t)o permit (a third) retrial, after 21 of 24 jurors have already refused to convict, is to ignore the reasonable doubt standard."

Summary of this case from Ex Parte Anderson

In United States v Ingram (412 F. Supp. 384, 386) the court reasoned, apart from double jeopardy principles, that a third trial after two previous jury disagreements, in the absence of new evidence, would amount to a disregard of the reasonable doubt standard.

Summary of this case from People v. Kirby
Case details for

United States v. Ingram

Case Details

Full title:UNITED STATES of America v. Edward C. INGRAM

Court:United States District Court, D. Columbia

Date published: Jan 7, 1976

Citations

412 F. Supp. 384 (D.D.C. 1976)

Citing Cases

United States v. Wright

United States v. Wright, Crim. A. No. 14-292, 2017 WL 1179006, at *4 (W.D. Pa. Mar. 30, 2017). It reasoned…

State v. Roper

Id. at 615-616. See, also, United States v. Ingram (D.D.C. 1976), 412 F. Supp. 384, 385 (Dismissal of…