Bravo-Fernandez v. United States

Juan Bravo-Fernandez and Hector Martínez-Maldonado were convicted of federal program bribery and conspiracy for providing a trip to a Puerto Rican senator. The same jury acquitted them on other charges related to a separate trip but could not reach a verdict on parallel Travel Act counts for both trips. The government sought to retry the hung counts. The defendants argued that the acquittals, based on identical facts, should bar retrial under the Double Jeopardy Clause's issue-preclusion doctrine. The district court and First Circuit denied the motion. The Supreme Court granted certiorari to decide whether issue preclusion applies when an acquittal is accompanied by a hung count on a charge sharing the same essential facts, creating inconsistent outcomes.

The Supreme Court unanimously affirmed the First Circuit, holding that the Double Jeopardy Clause did not bar retrial. The Court reasoned that because the jury’s acquittals and its failure to agree on other counts were irreconcilably inconsistent, it was impossible to determine with certainty what factual issues the jury necessarily resolved in reaching the acquittals. Therefore, the acquittals carried no issue-preclusive effect for the hung counts.

Whether the issue-preclusion component of the Double Jeopardy Clause bars a retrial on counts where the jury hung, when the same jury acquitted the defendants on related counts predicated on the same factual core, producing rationally irreconcilable verdicts.

The decision narrowed the application of collateral estoppel in criminal cases involving inconsistent verdicts, granting prosecutors broader latitude to retry deadlocked charges even after factually related acquittals. It clarified that issue preclusion requires a rational and consistent verdict, influencing multi-count conspiracy, bribery, and corruption trials by allowing the government to avoid technical Double Jeopardy bars arising from jury compromises.