People v. Griswold
Defendant Griswold was convicted of murder in the second degree and arson after a retrial on a felony murder count where the initial jury had been unable to agree. Griswold appealed, contending that the retrial violated double jeopardy and that incriminating statements made to police were admitted in contravention of his right to counsel. The court affirmed the trial court's discretion in declaring a mistrial, thus rejecting the double jeopardy claim. However, applying recent precedents from People v Cunningham and People v Pepper retroactively, the court found that the jury instruction regarding the voluntariness of Griswold's statements was prejudicially incorrect, as it did not require a prior determination of whether he had requested counsel. Consequently, the conviction was reversed, and a new trial was ordered.