Judge Steve O'Neill declared a mistrial after jurors deliberated for over 50 hours without being able to reach a unanimous decision.
Constand met Cosby at Temple when she worked there as director of operations for the university's women's basketball team.
It's likely that Cosby's defence team will try to block a new trial, but legal experts say they are unlikely to prevail.
Bill Cosby's wife, Camille, lashed out at the judge, Steven O'Neill, accusing him of "collaborating with the district attorney", and for being "overtly arrogant". Montgomery County prosecutors then filed charges against him.
Cosby, who turns 80 next month, was subdued and seemed nearly dazed when O'Neill declared the mistrial.
In addition to proving that Cosby assaulted them, Smolla said, they would have to establish that he said something about them beyond denying the allegations, such as calling them known liars or promiscuous.
The comedian also faces a defamation lawsuit by model Janice Dickinson, who claims Cosby drugged and raped her in Lake Tahoe, California, in 1982. Her client in that case has accused Cosby of raping her at the Playboy mansion when she was just 15 years old.
There are many other variables to consider for the next trial - like what people already know about the case and whether Constand will elaborate on any new details, even whether new witnesses are called.
One of Bill Cosby's accuser's reacts at the Montgomery County Courthouse after a mistrial the Bill Cosby sexual assault case in Norristown, Pa., Saturday, June 17, 2017. They had reported being deadlocked Thursday but then resumed deliberations at the request of the judge.
"She's a very spiritual woman, she believes things happen for a goal, and I think the objective is.it should encourage other women to come forward and have their day in court", said her lawyer, Dolores Troiani.
A decade later, a new district attorney reopened the investigation after Cosby's lurid testimony about drugs and sex became public, and dozens of women came forward against one of the most beloved stars in all of show business.
Callan said the $33.5 million awarded in the case reflected the jury's reaction to a double homicide and was larger than a potential award to someone who has civil claims against Cosby.
"This was about Andrea Constand and inconsistencies in her story".
"I have seen it many times in cases all over the country, and sometimes a second jury will render a different outcome than the first jury".
"Mr. Cosby's power is back". She also recalled a Los Angeles case where an 11-1 vote to acquit in the first trial ended with a conviction the second time around. There's still so much to be said, ' he said.
"She has shown such courage through this, and we are in awe of what she has done", District Attorney Kevin Steele said.
But he maintained he only gave accuser Andrea Constand three half-tablets of Benadryl to help her relax. There is not today in my mind at least, as a layman, a case that exists that stands within the statute of limitations that has physical evidence, corroborative evidence, the kind of testimony you would need to convict him.
Yet the fundamental potential flaw in the case will remain: Constand's inconsistent statements to police about matters such as the date and circumstances of the alleged assault, which she says took place in 2004 at Cosby's gated estate in tony Elkins Park, Pennsylvania.