Renico v. Lett

Background

Reginald Lett, a man tried in Michigan for murder, faced a jury that deliberated roughly four hours and sent several notes to the judge. After a three-minute exchange with the jury foreperson, the judge declared a mistrial and later scheduled a new trial. Lett was convicted at retrial and challenged the mistrial as violating his protection against being tried twice for the same charge. A federal court granted him relief, and an appeals panel affirmed, prompting review here.

Reasoning

The core question was whether the Michigan Supreme Court’s decision allowing a new trial after the mistrial was an unreasonable application of federal habeas law. The Court stressed that a federal statute (AEDPA) requires federal judges to give state-court decisions a high level of deference. Applying that deferential standard, the Court found the state court’s conclusion—that the trial judge had not abused her discretion in declaring a mistrial—was not objectively unreasonable, so federal habeas relief was improper.

Real world impact

The decision means federal courts will be less likely to overturn state rulings that allow retrials after judges declare mistrials for allegedly deadlocked juries. Defendants arguing they were wrongly retried will face a tougher path in federal habeas proceedings because federal judges must respect reasonable state-court judgments under AEDPA. The ruling leaves open the possibility that truly egregious mistrials could still be remedied.

Dissents or concurrances

Justice Stevens, joined in part by two colleagues, sharply disagreed, saying the trial judge acted precipitately, violated the defendant’s right not to be tried twice, and that federal review should have corrected that error.