Renico v. Lett
2010 United States Supreme Court case

Renico v. Lett, 559 U.S. 766 (2010), was a United States Supreme Court case in which the court held that the trial court's decision in this case was not unreasonable under the Antiterrorism and Effective Death Penalty Act of 1996. A federal habeas court must be deferential to the state trial court, including its decision about whether a jury was deadlocked.
Background
From jury selection to jury instructions in a Michigan court, Lett's first trial for, among other things, first-degree murder took less than nine hours. During approximately four hours of deliberations, the jury sent the trial court seven notes, including one asking what would happen if the jury could not agree. The judge called the jury and the attorneys into the courtroom and questioned the foreperson, who said that the jury was unable to reach a unanimous verdict. The judge then declared a mistrial, dismissed the jury, and scheduled a new trial. At Lett's second trial, after deliberating for only 3 hours and 15 minutes, a new jury found him guilty of second-degree murder.
On appeal within the state's system, Lett argued that because the judge in his first trial had announced a mistrial without any manifest necessity to do so, the Double Jeopardy Clause barred the state from trying him a second time. Agreeing, the Michigan Court of Appeals reversed the conviction.
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