(CN) – The Supreme Court on Monday reinstated the second-degree murder conviction of a man who said the trial judge unnecessarily declared a mistrial after just four hours of jury deliberations. The 7-3 majority acknowledged that the judge “could have been more thorough,” but said it wasn’t up to federal courts to “second-guess the reasonable decisions of state courts.”
In the case of Reginald Lett, the Michigan Supreme Court reversed the state appeals court’s ruling vacating his conviction after a second trial. The state justices ruled that Lett’s conviction did not violate the double jeopardy clause, which bars multiple trials over the same alleged crime.
Lett argued that the first trial judge announced a mistrial without any “manifest necessity” for doing so. Jurors had sent the judge seven notes, one of which asked, “What if we can’t agree? Mistrial? Retrial? What?”
The judge asked the foreperson if the jury would reach a unanimous verdict. The foreperson said no, and judge declared a mistrial. A second jury found Lett guilty of second-degree murder in the fatal shooting of a taxi driver at a Detroit liquor store.
When Lett’s appeals failed at the state-court level, he filed a federal habeas petition.
A federal judge granted his petition, and a split panel of the 6th Circuit in Cincinnati affirmed.
Michigan appealed to the nation’s top court, arguing that federal courts should defer to state courts on habeas review.
The majority agreed and held that the Michigan Supreme Court had acted reasonably in reinstating Lett’s conviction.
“[T]he Michigan Supreme Court’s decision upholding the trial judge’s exercise of discretion — while not necessarily correct — was not objectively unreasonable,” Chief Justice John Roberts Jr. wrote. He said the 6th Circuit “failed to grant the Michigan courts the dual layers of deference” required by federal law.
Dissenting Justice John Paul Stevens took issue with the trial judge’s ruling, saying it deprived Lett of his right to a fair trial. “The record suggests that she discharged the jury without considering any less extreme courses of action and … did not fully appreciate the scope or significance of the ancient right at stake.”
Justices Sonia Sotomayor and Stephen Breyer joined Steven’s dissent.