A MANUAL OF JURY TRIAL PROCEDURES - 2004
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Chapter Three: The Trial Phase

3.20  Permitting Government to Reopen After Motion for Judgment of Acquittal

"A district court is afforded wide discretion in determining whether to allow the government to reopen and introduce evidence after it has rested its case." United States v. Suarez-Rosario, 237 F.3d 1164, 1167 (9th Cir. 2001) (citation omitted). "One purpose of [Fed. R. Crim P.] Rule 29 motions is to alert the court to omitted proof so that, if it so chooses, it can allow the government to submit additional evidence." Id. (citations omitted).