Blueford v. Arkansas, 566 U.S. 599 (2012), was a decision of the Supreme Court of the United States that clarified the limits of the Double Jeopardy Clause.

Writing for the majority, Chief Justice Roberts held that because the jury did not formally acquit on any charges, the report of the foreperson that the jury had unanimously voted against capital murder and first-degree murder "lacked the finality" required to prevent a retrial.

Further, Chief Justice Roberts found that the trial court's declaration of a mistrial was proper under the circumstances.

Accordingly, the Supreme Court of Arkansas held that the Double Jeopardy Clause did not prohibit Blueford's retrial.

Blueford asserted that even though the jury had not filled out a formal form verdict, the foreperson's clear announcement in open court that the jury had unanimously voted to acquit Blueford of charges constituted a final verdict of acquittal.

The prosecution also contended that the trial judge's instructions that the jury unanimously vote that there was a reasonable doubt on one charge before discussing a lesser included charge did not require the jury to "acquit" Blueford because jurors could change their minds.

Conversely, the National Association of Criminal Defense Lawyers submitted a brief in support of Blueford asserting that partial verdicts should be required because the importance of double jeopardy protection outweighs any potential coercive effects on jurors.

[10] Writing for the majority, Chief Justice Roberts held that the foreperson's announcement to the trial court that the jury had unanimously voted to acquit on the charges of capital murder and first-degree murder did not constitute a verdict of acquittal because the jury resumed deliberating after the announcement: The foreperson's report was not a final resolution of anything.

[...] It was therefore possible for Blueford's jury to revisit the offenses of capital and first-degree murder, notwithstanding its earlier votes.

And because of that possibility, the foreperson's report prior to the end of deliberations lacked the finality necessary to amount to an acquittal on those offenses, quite apart from any requirement that a formal verdict be returned or judgment entered.

[11] The Court further held that the Constitution does not require states to accept "partial verdicts" before declaring a mistrial in order to retry a defendant in accordance with the Double Jeopardy Clause.

Justice Sotomayor wrote that the foreperson's announcement that the jury had unanimously voted against conviction on capital and first-degree murder constituted an acquittal under governing law: [T]he forewoman's announcement in open court that the jury was "unanimous against" conviction on capital and first-degree murder was an acquittal for double jeopardy purposes.

[15] Following the Supreme Court's decision, legal analyst Andrew Cohen, writing in The Atlantic, criticized the case as excessively narrowing the protections of the Double Jeopardy Clause, writing that "[t]he fact that it was theoretically possible that the jury could have changed its mind on the Blueford acquittals (during those 31 minutes of additional deliberations) was enough for Roberts and company to reward prosecutors with a second chance to convict Blueford of capital murder.

[19] In June 2013, Blueford made no-contest plea to the first degree murder before a judge in the Pulaski County, Arkansas.

In exchange for the plea, prosecutors dropped the charge of capital murder and offered a 10-year prison sentence.