Supreme Court of the United States
Paul Renico v. Reginald Lett
May 3, 2010176 L. Ed. 2d 678
Summary
The Supreme Court reversed the Sixth Circuit's affirmance of a federal habeas writ granted to Reginald Lett, holding that the Michigan Supreme Court's determination that the trial judge exercised sound discretion in declaring a mistrial after a deadlocked jury was not an objectively unreasonable application of clearly established federal law under 28 U.S.C. § 2254(d)(1). Because an unreasonable application differs from an incorrect one, and because the general 'sound discretion' standard gives state courts added leeway, the state court's reliance on the length of deliberations, the jury's notes, and the foreperson's express prediction that no verdict would be reached was reasonable even if not necessarily correct. The Court further held that the Sixth Circuit's Fulton decision is not 'clearly established Federal law' under AEDPA and that Arizona v. Washington established no three-factor constitutional test for mistrial discretion. Justice Stevens, dissenting, joined by Justice Sotomayor and as to Parts I and II by Justice Breyer, would have found the mistrial precipitate and unlawful and objected to the majority's 'dual layers of deference.'
Holding
- Whether the Michigan Supreme Court's rejection of Lett's double jeopardy claim was an objectively unreasonable application of clearly established federal law under AEDPA § 2254(d)(1).. It was not. The Michigan Supreme Court's adjudication was a straightforward application of Perez and Washington, and in light of the four hours of deliberation after a short, uncomplicated trial, the jury's notes, and most importantly the foreperson's express statement that the jury would not reach a verdict, it was reasonable for the state court to conclude the trial judge exercised sound discretion in declaring a mistrial.
- Whether the Sixth Circuit properly relied on its own decision in Fulton v. Moore, and its three-factor reading of Arizona v. Washington, in granting habeas relief.. It did not. Fulton does not constitute 'clearly established Federal law, as determined by the Supreme Court' under § 2254(d)(1), so any failure to apply it cannot independently authorize habeas relief; nor can Fulton be understood merely to illuminate Washington, because Washington nowhere established the three factors (hearing counsel, considering alternatives, acting deliberately rather than abruptly) as a constitutional test determining whether a judge exercised sound discretion.
Docket No. 09-338