May 03, 2010

Supreme Court Decides Renico v. Lett

On May 3, the Supreme Court decided Renico v. Lett, No. 09-338, holding that the Michigan Supreme Court's conclusion that the double-jeopardy clause did not bar a defendant's retrial after the jury at the first trial deadlocked was not an "unreasonable application of . . . clearly established Federal law as determined by the Supreme Court," and the federal courts therefore erred in granting habeas corpus relief from the defendant's conviction upon retrial.

Reginald Lett was tried for first-degree murder in a Michigan state court in a trial lasting less than nine hours. Over two days of deliberations, the jury repeatedly sent notes to the trial judge indicating that the deliberations had become heated, and eventually they indicated that they were deadlocked. The judge declared a mistrial and set the case for a retrial, at which Lett was convicted of second-degree murder after only brief jury deliberations. Lett appealed his conviction, and the Michigan Court of Appeals held that the retrial violated the Double Jeopardy Clause of the Constitution. But the Michigan Supreme Court reversed, citing U.S. Supreme Court precedent holding that a mistrial may be declared when a jury deadlocks, and the defendant may be retried without double-jeopardy implications, so long as the trial court exercises its "sound discretion" in concluding that there is a "manifest necessity" for a mistrial. Lett then filed a petition in federal court for a writ of habeas corpus. The federal district court granted his petition and the Sixth Circuit affirmed.

The Supreme Court reversed. It stressed that the question raised by the habeas petition was not whether the trial judge should have declared a mistrial or even whether it was an abuse of discretion for her to have done so; those questions were resolved in the direct review of the conviction in Michigan state court. Rather, in light of the Antiterrorism and Effective Death Penalty Act of 1996, the question was whether the Michigan Supreme Court's conclusions that there was no abuse of discretion was "an unreasonable application of . . . clearly established Federal law." And an unreasonable application of federal law is a substantially higher threshold for relief than an incorrect application, making the standard for granting habeas relief highly deferential toward the state-court ruling. Applying this standard, the Court found that, although the trial court "could have been more thorough before declaring a mistrial," the Michigan Supreme Court correctly stated the long-established federal law governing Lett's double-jeopardy claim. Its application of that law, which required significant deference to the trial court's decision was not "objectively unreasonable," whether or not it was "correct." The Sixth Circuit also erred in basing its decision partly on one of its own double-jeopardy decisions, because habeas relief must be based on an unreasonable application of federal law as clearly established by the Supreme Court.

Chief Justice Roberts delivered the opinion of the Court, in which Justices Scalia, Kennedy, Thomas, Ginsburg, and Alito joined. Justice Stevens filed a dissenting opinion, in which Justice Sotomayor joined and Justice Breyer joined in part.

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