Thanks—that’s new information for me: 0>JJ<4. I hadn’t given any thought to, nor read anything about, the mechanics of those conferences. However, couldn’t it also be on occasion that for some unrelated reason they simply didn’t address it at all during the first conference?
Possibly, yes, but unlikely. There are a huge number of cases on the agenda for every conference, but most of them are not discussed at all-- before each conference, each justice circulates a list of cases that they actually want to talk about. Roughly 90% of cases aren't on any justice's list, so they're "dead listed"-- they aren't discussed, and an order denying cert. is issued automatically.
So we know for a fact that at least one justice wanted to talk about this case. We also know for a fact that there were not four votes to grant cert., or cert. would have been granted. So my gut tells me that there were 1-3 votes for cert. and one or more justices who said, "maybe, let me think about it."
It's possible that the conference went on for so long that they just didn't get to this case, but I don't think that happens often.