Evans v. Michigan
In brief
Evans won: the Supreme Court overturned Michigan’s ruling and barred the state from trying him again for this offense.
- Where it stands
- Decided
Decided 8-1 · February 20, 2013 · Opinion by Justice Sotomayor
- What it’s about
- The Supreme Court ruled that the Constitution’s protection against a second trial for the same offense (the Double Jeopardy Clause) bars Michigan from retrying Lamar Evans, even though the trial judge wrongly treated whether the building was a dwelling as an element and acquitted him after the state failed to prove it.
- Who it affects
- Michigan cannot retry Evans for this offense, even though the trial judge made a legal mistake.
Summary: written with AI from the case record.
What it's about
The Court overturned the Michigan Supreme Court’s decision.
The Double Jeopardy Clause protects a person from a second trial for the same offense after an acquittal.
Question presented
Does the Double Jeopardy Clause bar retrial after the trial judge wrongly holds a particular fact to be an element of the offense and then grants a directed verdict of acquittal because the prosecution failed to prove that fact?
What the Court decided
Holding
The Double Jeopardy Clause bars retrial for Evans’ offense. Pp. 4 − 17. 491 Mich. 1, 810 N. W. 2d 535, reversed.
- Result
- Reversed
The Court's reasoning
The Court treated the trial judge’s ruling as an acquittal for double-jeopardy purposes even though it rested on a mistaken view of what prosecutors had to prove.
The vote
From the opinions
“For no good reason, the Court deprives the State of Michigan of its right to have one fair opportunity to convict petitioner, and I therefore respectfully dissent.”
What's next
Michigan cannot retry Evans for this offense under the Court’s ruling.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Evans
Opinion added: Evans
More questions
- Why did Justice Alito disagree?
- He argued the judge’s ruling was not an acquittal because it did not resolve whether Evans was guilty, and Michigan should get one fair chance to convict him.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.