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 'hopelessly deadlocked' and discharged. Six days later, the respondent corporations filed timely motions for judgments of acquittal under Federal Rule of Criminal Procedure 29(c), which the District Court granted. The United States sought to appeal these judgments of acquittal.

Issue

Are judgments of acquittal entered by a District Court under Federal Rule of Criminal Procedure 29(c) after a jury is discharged due to deadlock appealable by the United States under 18 U.S.C. § 3731, or are they barred by the Double Jeopardy Clause?

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 they are barred by the Double Jeopardy Clause.

Rule

The Double Jeopardy Clause bars government appeals from judgments of acquittal, regardless of whether they are based on a jury verdict or a judge's ruling under Rule 29(c) that evaluates the sufficiency of the evidence. An acquittal, for double jeopardy purposes, is any ruling that resolves some or all of the factual elements of the offense, and such a ruling cannot be reviewed without putting the defendant twice in jeopardy.

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Case brief last reviewed 2026-01-08. Prepared by CaseReader from the published opinion.