State v. Johnson

The trial judge heard all of the evidence against Michael Johnson and pronounced it insufficient. By granting a motion pursuant to Rule 4-324, the judge said, in effect, that there was “no relevant evidence [that] is legally sufficient to sustain a conviction.” Brooks v. State, 299 Md. 146, 151, 472 A.2d 981 (1984). That is powerful stuff. Once that happens, we don’t *514usually give the State a second (or in this case, third) bite at the apple. Prohibitions on placing defendants in double jeopardy, whether arising from federal constitutional or state common law principles,1 bar subsequent…