The US Supreme Court [official website; JURIST news archive] on Monday ruled [opinion, PDF] 6-3 in Renico v. Lett [Cornell LII backgrounder; JURIST report] that double jeopardy is not violated by a new trial after a state trial court declared a mistrial due to the jury's inability to reach a verdict. The US Court of Appeals for the Sixth Circuit affirmed [opinion, PDF] the decision of the district court that the second trial violated the rights of the defendant, Reginald Lett. The decision overturned a decision by the Michigan Supreme Court, which found that the second trial did not violate the double jeopardy bar. The Supreme Court reversed, ruling that the Sixth Circuit failed to properly defer to the Michigan court under the Antiterrorism and Effective Death Penalty Act (AEDPA) [text, PDF]. Chief Justice John Roberts wrote:
This case requires us to review the grant of a writ of habeas corpus to a state prisoner under the [AEDPA]. The District Court in this case issued the writ to respondent Reginald Lett on the ground that his Michigan murder conviction violated the Double Jeopardy Clause of the Constitution, and the U. S. Court of Appeals for the Sixth Circuit affirmed. In doing so, however, these courts 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.Justice John Paul Stevens filed a dissenting opinion, joined by Justice Sonia Sotomayor and joined in part by Justice Stephen Breyer.
In Lett's first trial on murder charges, the judge declared that the jury was deadlocked and declared a mistrial. A second trial was held, in which Lett was convicted of second-degree murder. The Michigan Supreme Court affirmed his conviction, and he filed a federal writ of habeas corpus.