People v. Sierb

In People v. Sierb, 456 Mich. 519, 581 N.W.2d 219 (Mich. 1998), the defendant moved to dismiss arson charges after two mistrials based upon hung juries. The trial court found that a new trial would be "fundamentally unfair" and dismissed the charges with prejudice. 581 N.W.2d at 220. A divided court of appeals affirmed. Id. The Michigan Supreme Court, however, reversed. While acknowledging that a number of courts had declared their inherent authority over the administration of justice to preclude retrials attributable to jury deadlock, the Michigan court "rejected the rationale that the administration of justice confers authority on this Court to allocate resources available to law enforcement . . . or to assess the relative priority of discrete charges in a given community." Sierb, 581 N.W.2d at 222.