U.S. SUPREME COURT UPHOLDS CRIMINAL CONVICTION

The Supreme Court has upheld the conviction of a Michigan Defendant. In Renico v. Lett, the Court held that jeopardy did not attach when a Trial Judge dismissed a deadlocked jury; the Judge had found the jury to have sufficiently deliberated.

In this holding, the Supreme Court made clear that no bright line rule will be adopted in determining whether a jury has sufficiently deliberated before declaring a mistrial. The Court also held that the Michigan Supreme Court's original denial of relief, which was overturned by the Sixth Circuit, was not an unreasonable application of federal law. Accordingly, the Sixth Circuit erred in granted relief under 28 U.S.C. 2254.

SUPREME COURT UPHOLDS MURDER CONVICTION

The Supreme Court has upheld a murder conviction. In Wood v. Allen, the Court held that it was not ineffective for trial attorneys to ignore a possible defense of cognitive deficiencies when the attorneys were in possession of a report that cast doubt as to whether such deficiencies actually limited the Defendant's functioning.

In so ruling, the Court stressed that an ineffective assistance claim cannot prevail when a trial attorney is employing reasonable strategy. Given that such has been the law for years, it is surprising that the Court would take up this issue; the Court likely only took this issue as the Circuit Court of Appeals had reversed the District Court's upholding of the conviction.

Justices Stevens and Kennedy were the only dissenters.