Renico v. Lett
559 U. S. ____ (2010) (2010)
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Rule of Law:
Under the Antiterrorism and Effective Death Penalty Act (AEDPA), a federal court may not grant habeas corpus relief to a state prisoner challenging a retrial on double jeopardy grounds unless the state court's decision—that the trial judge exercised sound discretion in declaring a mistrial for jury deadlock—was an objectively unreasonable application of clearly established federal law.
Facts:
- An argument occurred at a Detroit liquor store involving taxi driver Adesoji Latona, passenger Charles Jones, and Reginald Lett, a friend of Jones.
- Lett left the liquor store, retrieved a handgun from a friend in the parking lot, and returned inside.
- Lett shot Latona twice, once in the head and once in the chest.
- Latona died from his wounds shortly thereafter.
- During Lett's first murder trial, the jury sent a note to the judge asking, 'What if we can't agree? [M]istrial? [R]etrial? [W]hat?'
- In a subsequent exchange, the trial judge asked the jury foreperson if the jury was going to reach a unanimous verdict.
- The foreperson hesitated and then, when pressed for a 'Yes or no' answer, replied, 'No, Judge.'
Procedural Posture:
- Reginald Lett was charged with murder and a firearm offense in a Michigan state trial court.
- Lett's first trial ended when the judge declared a mistrial, concluding the jury was deadlocked.
- Following a second trial, Lett was convicted of second-degree murder.
- Lett, as appellant, appealed to the Michigan Court of Appeals, an intermediate appellate court.
- The Michigan Court of Appeals reversed Lett's conviction, finding the second trial violated the Double Jeopardy Clause.
- The State of Michigan, as appellant, appealed to the Michigan Supreme Court, the state's highest court.
- The Michigan Supreme Court reversed the Court of Appeals' decision and reinstated Lett's conviction.
- Lett filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of Michigan.
- The U.S. District Court granted the writ of habeas corpus.
- The State of Michigan, as appellant, appealed to the U.S. Court of Appeals for the Sixth Circuit.
- The Sixth Circuit affirmed the District Court's grant of the writ.
- The State of Michigan petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Under the Antiterrorism and Effective Death Penalty Act (AEDPA), was the Michigan Supreme Court's determination that the trial judge exercised sound discretion in declaring a mistrial due to jury deadlock an unreasonable application of clearly established federal law, thereby violating the Double Jeopardy Clause?
Opinions:
Majority - Chief Justice Roberts
No. The Michigan Supreme Court's decision was not an unreasonable application of clearly established federal law. A trial judge's declaration of a mistrial due to jury deadlock is entitled to great deference, and under AEDPA, a federal court must apply a second layer of deference to the state court's review of that decision. A federal court may not issue a writ of habeas corpus simply because it disagrees with the state court's conclusion; the state court's application of federal law must be 'objectively unreasonable.' Here, the Michigan Supreme Court reasonably concluded that the trial judge did not abuse her discretion, considering the foreperson’s explicit statement that the jury would not reach a verdict, the jury's note indicating deadlock, and the length of deliberations relative to the trial's complexity. The Sixth Circuit erred by imposing its own rigid, three-factor test derived from circuit precedent, as this does not constitute 'clearly established Federal law' as determined by the Supreme Court.
Dissenting - Justice Stevens
Yes. The Michigan Supreme Court's decision was an unreasonable application of clearly established federal law. A defendant’s right to have their trial completed by a particular tribunal is a fundamental aspect of the Double Jeopardy Clause, and a mistrial is only permissible upon a showing of 'manifest necessity.' The trial judge in this case acted precipitately and irresponsibly by declaring a mistrial after a brief and flawed colloquy with the foreperson, without considering any alternatives, and without giving counsel an opportunity to be heard. The judge conflated mere disagreement with deadlock and cut off the foreperson's potentially explanatory answer. The Michigan Supreme Court unreasonably upheld this decision by relying on a superficial review of the facts and ignoring the judge's clear failure to exercise the 'sound discretion' required by Supreme Court precedent.
Analysis:
This case significantly reinforces the high barrier for federal habeas corpus relief established by AEDPA, particularly when reviewing discretionary decisions made by state trial courts. It establishes a 'dual deference' standard: deference to the trial judge's finding of a deadlocked jury and deference to the state appellate court's review of that finding. The decision clarifies that for a federal court to find a state court's application of a general legal standard (like 'sound discretion') unreasonable, the state court's decision must be more than simply incorrect; it must fall outside the wide range of plausible, fair-minded outcomes. This holding strengthens the finality of state court convictions and limits the scope of federal oversight in double jeopardy cases involving mistrials.
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