Appealed from the United States Court of Appeals for the Sixth Circuit (March 10, 2009)
Oral argument: March 29, 2010
AEDPA, DOUBLE JEOPARDY, HABEAS CORPUS, MISTRIAL, MANIFEST NECESSITY, FIFTH AMENDMENT
Reginald Lett was convicted of second-degree murder in a Michigan state court in his second trial for the same offense. In his first trial, the judge determined that the jury was deadlocked and declared it a mistrial. Lett then filed a petition for a writ of habeas corpus in the Federal District Court for the Eastern District of Michigan. His petition was granted. On appeal, the Sixth Circuit Court of Appeals affirmed the district court’s ruling on the basis that Lett’s Fifth Amendment right to be free from Double Jeopardy had been violated because the trial court had not used “sound discretion” in finding a “manifest necessity” to declare a mistrial and terminate the ongoing proceedings. This case presents the Supreme Court with the opportunity to clearly articulate what state courts must do before declaring a mistrial to avoid running afoul of the Fifth Amendment.