Newton was convicted in September 1968 of voluntary manslaughter for the killing of Frey and was sentenced to 2 to 15 years in prison. In May 1970, the California Appellate Court reversed the conviction and ordered a new trial. After two subsequent trials ended in hung juries, the district attorney said he would not pursue a fourth trial, and the Alameda County Superior Court dismissed the charges. In his autobiography, "Revolutionary Suicide", Newton wrote that Heanes and Frey were opposite each other and shooting in each other's direction during the shootout.