Did Trial Court Establish 'Manifest Necessity' for Mistrial Before Ordering New Trial in Murder Case?

2nd District Court of Appeals (Clark County)

ISSUE: After learning that a juror in a criminal case had done improper independent research after jury deliberations were underway, did the trial judge violate the defendants' double jeopardy rights by granting a motion by the state for a mistrial without first examining the juror regarding her ability to disregard the results of her improper research or conducting a hearing at which double jeopardy issues and alternatives to a mistrial were thoroughly considered?