In State v. Connors, the Washington State Supreme Court held that a defendant had been placed in jeopardy when, sua sponte, a trial court erroneously declared a mistrial over his objection. A later retrial of the defendant therefore constituted double jeopardy.
David W. Sandell,
Washington Case Law,
Criminal Law—Double Jeopardy,
Wash. L. & Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol38/iss2/7