People v. Lett

Summary

The Michigan Supreme Court held that a retrial following a mistrial caused by jury deadlock did not violate the Double Jeopardy Clauses of the federal or Michigan constitutions. The court concluded that the trial judge did not abuse her discretion in declaring a mistrial after the jury foreperson stated that the jury would not reach a unanimous verdict, particularly because the defendant did not object. The court reversed the Court of Appeals and remanded for consideration of an unresolved additional issue.

Holdings

1. A trial court does not abuse its discretion by declaring a mistrial where the jury expressly indicates that it will not reach a unanimous verdict, even when the court does not first examine alternatives, conduct a separate manifest-necessity hearing, or make explicit findings on the record.
2. The Double Jeopardy Clauses of the United States and Michigan Constitutions did not bar defendant's retrial or convictions because the mistrial was properly declared on the basis of manifest necessity arising from jury deadlock.

Questions Presented

1. Whether the trial court abused its discretion and lacked manifest necessity when it declared a mistrial after the jury foreperson stated that the jury would not reach a unanimous verdict.
2. Whether defendant's retrial after the jury-deadlock mistrial violated the Double Jeopardy Clauses of the United States and Michigan Constitutions.

Disposition

reversed_and_remanded