Legal Research

"U.S. Supreme Court Strikes Down Habeas Corpus Grant Based on Double Jeopardy Clause"

This post was written by Chuck Kallendorf: "Anna Christensen and Stanford's Alex Harris at ScotusBlog, last Tuesday reported on the U.S. Supreme Court decision in Renico v. Lett , No. 09-338.

"At issue in the case," they summarized, "was the trial judge's decision to declare a mistrial in respondent Reginald Lett's first trial on first-degree murder charges. Neither Lett nor the state had asked for a mistrial on the record; after four hours of deliberations, the jury had sent the judge a note asking what would happen if it could not agree. In his second trial, the jury found Lett guilty. He appealed, arguing that the Double Jeopardy Clause prohibited the state from trying him again. The Michigan Court of Appeals agreed and reversed his conviction, but it was then in turn reversed by the Michigan Supreme Court. Relying on the U.S. Supreme Court's holding nearly two hundred years ago in United States v. Perez, that court reasoned that a new trial after a mistrial does not violate the Double Jeopardy Clause as long as there was a 'manifest necessity' for the mistrial, as reflected by the trial judge's exercise of its 'sound discretion'; moreover, the Michigan Supreme Court noted, the U.S. Supreme Court has subsequently held that appellate courts must generally defer to the trial judge's determination that the jury is deadlocked."

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Source: Hamilton County Law Library Blog, 6 May 2010. Reproduced with permission.

Full post as published by Stark County Law Library Blawg on May 07, 2010 (boomark / email).