## Facts

- Reginald Lett was tried in Michigan state court for first-degree murder and felony-firearm arising from a 1996 shooting at a Detroit liquor store that killed taxi driver Adesoji Latona.
- At Lett’s first trial, the proceedings were short and uncomplicated, lasting less than nine hours over six days.
- The jury deliberated about four hours over two days and sent seven notes, including a question about what would happen if it could not agree.
- The trial judge questioned the foreperson, who stated the jury was unable to reach a unanimous verdict.
- The judge declared a mistrial due to deadlock, dismissed the jury, and set the case for retrial.
- At the second trial, a new jury convicted Lett of second-degree murder (and felony-firearm) after approximately three hours and fifteen minutes of deliberation.

## Issues

1. Whether, under 28 U.S.C. § 2254(d)(1), the Michigan Supreme Court unreasonably applied clearly established Double Jeopardy precedent in concluding the trial judge did not abuse discretion in declaring a mistrial for jury deadlock.
2. Whether AEDPA permits a federal habeas court to overturn a state court’s determination that there was “manifest necessity” for a mistrial when the jury reported itself unable to reach a verdict.

## Decision

- The U.S. Supreme Court reversed the Sixth Circuit’s grant of habeas relief.
- The Court held that the Michigan Supreme Court’s application of the “manifest necessity” standard to the mistrial declaration was not unreasonable under AEDPA.
- The Court emphasized that AEDPA limits relief to state-court decisions that are unreasonable, not merely incorrect.
- The Court rejected reliance on circuit-developed multi-factor tests as a substitute for “clearly established Federal law” defined by Supreme Court holdings.
- The Court noted there is no constitutional requirement that a judge impose a minimum deliberation time or give a supplemental instruction before declaring a mistrial for deadlock.

## Legal Principles

- Retrial after a mistrial declared for a genuinely deadlocked jury is consistent with the Double Jeopardy Clause when the trial judge exercises “sound discretion” and finds “manifest necessity.”
- Reviewing courts generally defer to a trial judge’s assessment that a jury is deadlocked, given the judge’s superior ability to evaluate the situation in real time.
- Under AEDPA, federal habeas relief is available only if the state court decision is contrary to, or an unreasonable application of, clearly established Supreme Court law.
- “Clearly established Federal law” for § 2254(d)(1) consists of Supreme Court holdings, not federal circuit precedent or circuit-created doctrinal tests.
- When the governing constitutional standard is general (such as “sound discretion”/“manifest necessity”), state courts have broader room to apply it; habeas relief requires more than disagreement with the outcome.

## Conclusion

The Court held that, even if other judges might have handled the deadlock differently, AEDPA barred federal habeas relief because the Michigan Supreme Court reasonably concluded that the mistrial declaration fell within the trial judge’s discretion and did not violate Double Jeopardy principles.


Renico v. Lett, 559 U.S. 766 (2010)