Renico v. Lett

The Supreme Court has agreed to decide whether the Michigan Supreme Court erred in denying a defendant's appeal on double jeopardy grounds where he was convicted of second-degree murder after his first trial resulted in a mistrial when the jury foreperson indicated that the jury could not reach a verdict.

The case concerns Reginald Lett, who was charged with first-degree murder and possession of a firearm during the commission of a felony in connection with a shooting death at a Detroit liquor store.

During the end of the second day of deliberations, the jury foreperson announced that the jury could not reach a unanimous verdict, and the judge declared a mistrial. Lett was subsequently retried on the same charges. The second jury convicted him of second-degree murder and felony-firearm, and he was sentenced to prison.

Lett appealed his conviction to the Michigan Court of Appeals, contending that his retrial violated the double-jeopardy prohibitions of the Michigan and U.S. Constitutions. The court agreed and reversed his conviction, but the Michigan Supreme Court dismissed the appeals court hold, finding that the retrial did not violate double jeopardy because the record contained "sufficient justification" for a finding that manifest necessity existed for declaring a mistrial.

Lett next filed a habeas corpus petition with the U.S. District Court for the Eastern District of Michigan, which sided with the Michigan Court of Appeals and concluded that the trial judge's decision to declare a mistrial was not required by manifest necessity and therefore constituted an abuse of discretion.

Last March, a three-judge panel on the 6th U.S. Circuit Court of Appeals agreed, upholding the district court's decision.

On Nov. 30, 2009, the U.S. Supreme Court agreed to hear the case.

Question presented: Whether the Sixth Circuit erred in holding that the Michigan Supreme Court failed to apply clearly established precedent by denying habeas relief on double jeopardy grounds when the state trial court declared a mistrial after the foreperson said that the jury was not going to be able to reach a verdict.

The Supreme Court held today that the Michigan Supreme Court correctly denied a defendant's appeal on double jeopardy grounds where he was convicted of second-degree murder after his first trial resulted in a mistrial when the jury foreperson indicated that the jury could not reach a verdict.

The case concerns Reginald Lett, who was charged with first-degree murder and possession of a firearm during the commission of a felony in connection with a shooting death at a Detroit liquor store.

During the end of the second day of deliberations, the jury foreperson announced that the jury could not reach a unanimous verdict, and the judge declared a mistrial. Lett was subsequently retried on the same charges. The second jury convicted him of second-degree murder and felony-firearm, and he was sentenced to prison.

Lett appealed his conviction to the Michigan Court of Appeals, contending that his retrial violated the double-jeopardy prohibitions of the Michigan and U.S. Constitutions. The court agreed and reversed his conviction, but the Michigan Supreme Court dismissed the appeals court holding, finding that the retrial did not violate double jeopardy because the record contained "sufficient justification" for a finding that manifest necessity existed for declaring a mistrial.

Lett next filed a habeas corpus petition with the U.S. District Court for the Eastern District of Michigan, which sided with the Michigan Court of Appeals and concluded that the trial judge's decision to declare a mistrial was not required by manifest necessity and therefore constituted an abuse of discretion.

Last March, a three-judge panel on the 6th U.S. Circuit Court of Appeals agreed, upholding the district court's decision.

On May 3, the Supreme Court reversed and remanded the lower court order in a 6-3 opinion by Chief Justice John Roberts.

The 6th Circuit "misapplied AEDPA’s deferential standard of review. Because we conclude that the Michigan Supreme Court’s application of federal law was not unreasonable, we reverse," the chief justice wrote in the majority opinion.

Justice John Paul Stevens dissented, joined by Justice Sonia Sotomayor and, in part, by Justice Stephen Breyer.

“Reginald Lett’s constitutional rights were violated when the trial court terminated his first trial without adequate justification, and he was subsequently prosecuted for the same offense,” Stevens wrote. "The majority does not appear to dispute this point, but it nevertheless denies Lett relief by applying a level of deference to the state court's ruling that effectively effaces the role of the federal courts."

Question presented: Whether the Sixth Circuit erred in holding that the Michigan Supreme Court failed to apply clearly established precedent by denying habeas relief on double jeopardy grounds when the state trial court declared a mistrial after the foreperson said that the jury was not going to be able to reach a verdict.