Santana v. State

Miguel Angel Santana v. State of Maryland, No. 19, September Term, 2025. Opinion by Eaves, J. CRIMINAL LAW – MISTRIAL – PROHIBITION ON DOUBLE JEOPARDY – NO RECKLESS STATE ACTION The Supreme Court of Maryland assumed—without deciding—that Maryland’s common law prohibition on double jeopardy bars a subsequent prosecution where the State’s reckless action caused a criminal defendant to successfully move for a mistrial. With that assumption, the Court held that the circuit court’s finding that the State did not engage in reckless conduct was not clearly erroneous. Therefore, the Court affirmed…