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Renico v. Lett

Supreme Court

559 U.S. 766 (2010)

Relevant factsFree

Lett (defendant) was tried for murder in a trial lasting under nine hours. After deliberating four hours, the jury sent a note asking what happens if they can't agree, and the judge asked the foreperson directly whether the jury would reach a unanimous verdict; the foreperson answered no. The judge declared a mistrial and discharged the jury without asking further questions or consulting counsel. At a second trial before a different jury, Lett was convicted after just over three hours of deliberation. Lett appealed on double jeopardy grounds, but the Michigan Supreme Court denied relief; a federal district court granted habeas relief, and the Sixth Circuit affirmed. The Supreme Court granted certiorari.

IssueFree

Whether a trial judge has broad discretion to declare a mistrial.

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