## Facts

- Brian Michael Aranda was tried on a single murder count for killing his teenage girlfriend’s father after going to her home in response to texts requesting help.
- Evidence showed Aranda encountered the girlfriend asleep in bed with her father, a fight began when Aranda tried to remove her, and Aranda fatally stabbed the father with an ice pick.
- The jury was instructed on first-degree murder, second-degree murder, and voluntary manslaughter, and received guilty verdict forms for each and a single not-guilty form.
- During deliberations, the jury reported conflict; the foreperson stated the jury had “ruled out” first-degree murder and was deadlocked between second-degree murder and voluntary manslaughter.
- The trial court treated the matter as a general deadlock, declined to take a partial verdict on first-degree murder, and declared a mistrial.
- The trial court later dismissed the first-degree murder allegation on double-jeopardy grounds but permitted retrial on second-degree murder and voluntary manslaughter.
- The Court of Appeal affirmed the bar to retrial on first-degree murder, and the California Supreme Court granted review to consider the effect of intervening federal precedent.

## Issues

1. Whether California law requires a trial court to accept a partial verdict of acquittal on a greater offense when the jury has clearly resolved it but is deadlocked on lesser included offenses.
2. Whether federal double-jeopardy doctrine precludes or displaces California’s partial-verdict requirement.
3. Whether the refusal to take a partial acquittal verdict rendered the mistrial on the greater offense lacking legal necessity, thereby barring retrial on that allegation.

## Decision

- The California Supreme Court affirmed the judgment barring retrial on the first-degree murder allegation.
- The court held that California’s constitutional double-jeopardy clause preserves the rule that a court must accept a partial acquittal verdict on a charged greater offense when the jury has clearly and unanimously resolved it in the defendant’s favor but is deadlocked on lesser included offenses.
- The court concluded the trial court erred by failing to receive a partial acquittal verdict on first-degree murder.
- Because that error made the mistrial declaration on first-degree murder “without legal necessity,” retrial on first-degree murder was prohibited.
- Retrial on lesser included offenses remained permissible because the jury had not finally resolved those offenses.

## Legal Principles

- Under the California Constitution, when a jury has clearly acquitted on a charged greater offense but cannot agree on lesser included offenses, the trial court must accept and record a partial verdict of acquittal on the greater offense.
- Federal double-jeopardy doctrine sets minimum protections and does not prevent California from providing broader protection as a matter of state constitutional law.
- If a court declares a mistrial on a charge despite the jury’s completed, unanimous acquittal on that charge, the mistrial is not supported by legal necessity and double jeopardy bars retrial on that charge.
- A defendant may be retried on lesser included offenses when the jury did not reach a final verdict on those offenses.

## Conclusion

California reaffirmed that a trial court must take a partial acquittal verdict on a greater offense once the jury has unmistakably resolved that charge, and a mistrial declared without doing so is not legally necessary; therefore, retrial for first-degree murder was barred even though retrial on unresolved lesser included offenses was allowed.


People v. Aranda, 437 P.3d 845 (Cal. 2019)