United States v. Martin Linen Supply Co.

51 L. Ed. 2d 642 · Supreme Court of the United States · 1977

Facts

A jury in a criminal contempt trial was discharged as "hopelessly deadlocked." The District Court subsequently granted the defendants' timely motions for judgments of acquittal under Federal Rule of Criminal Procedure 29(c), finding the evidence insufficient. The United States sought to appeal these acquittals, but the Court of Appeals held no appeal lay due to Double Jeopardy.

Issue

Can the United States appeal a judgment of acquittal entered by a district court under Federal Rule of Criminal Procedure 29(c) after a jury has been discharged due to deadlock, or does the Double Jeopardy Clause prohibit such an appeal?

Holding

The Supreme Court affirmed the Court of Appeals, holding that judgments of acquittal entered under Rule 29(c) are not appealable by the United States because the Double Jeopardy Clause prohibits further prosecution.

Rule

The Double Jeopardy Clause bars government appeals from judgments of acquittal that resolve factual elements of the offense, regardless of the timing of the judge's action (before, during, or after jury deliberations, including after a deadlocked jury is discharged). A successful appeal would necessitate a new trial, which is prohibited by the Clause.

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Case brief last reviewed 2026-01-07. Prepared by CaseReader from the published opinion.