Renico v. Lett - 559 U.S. 766, 130 S. Ct. 1855 (2010)

Rule:

The question under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) is whether the determination of a state court was an unreasonable application of clearly established federal law. 28 U.S.C.S. § 2254(d)(1). An unreasonable application of federal law is different from an incorrect application of federal law. Indeed, a federal habeas court may not issue the writ simply because that court concludes in its independent judgment that the relevant state-court decision applied clearly established federal law erroneously or incorrectly. Rather, that application must be "objectively unreasonable." This distinction creates a substantially higher threshold for obtaining relief than de novo review. AEDPA thus imposes a highly deferential standard for evaluating state-court rulings and demands that state-court decisions be given the benefit of the doubt.

Facts:

From jury selection to jury instructions in a Michigan court, respondent Lett’s first trial for, inter alia, 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 respondent’s second trial, after deliberating for only 3 hours and 15 minutes, a new jury found him guilty of second-degree murder. On appeal, respondent 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. The Michigan Supreme Court reversed, holding that under United States v. Perez, 22 U.S. 579, 9 Wheat. 579, 580, 6 L. Ed. 165, a defendant may be retried following the discharge of a deadlocked jury so long as the trial court exercised its “sound discretion” in concluding that the jury was deadlocked and thus that there was a “manifest necessity” for a mistrial; and that, under Arizona v. Washington, 434 U.S. 497, 506-510, 98 S. Ct. 824, 54 L. Ed. 2d 717, an appellate court must generally defer to a trial judge’s determination that a deadlock has been reached. In the respondent’s federal habeas petition, he contended that the Michigan Supreme Court’s rejection of his double jeopardy claim was “an unreasonable application of clearly established Federal law, as determined by the Supreme Court of the United States, and thus, he was not barred by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) from obtaining federal habeas relief. The District Court granted the writ, and the Sixth Circuit affirmed. The Supreme Court granted certiorari. 

Issue:

Was the respondent entitled to a federal habeas relief? 

Answer:

No.

Conclusion:

Because the Michigan Supreme Court’s decision in this case was not unreasonable under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), the Court held that the Sixth Circuit erred in granting respondent habeas relief. According to the Court, the state supreme court’s decision was not an unreasonable application of clearly established federal law under §  2254(d)(1). The state court identified the “manifest necessity” standard for declaring a mistrial and noted the broad deference due to trial courts in deciding whether that standard had been met. It was reasonable for the state court to have found that the trial court exercised sound discretion given the length of deliberations, the notes from the jury, and the foreperson’s statement. In holding otherwise, the Sixth Circuit erroneously relied on its own precedent, which was not “clearly established federal law, as determined by the Supreme Court” under §  2254(d)(1).