Stochastic optimization algorithms have become indispensable in modern machine learning. An unresolved foundational question in this area is the difference between with-replacement sampling and without-replacement sampling -- does the latter have superior convergence rate compared to the former? A groundbreaking result of Recht and R\'e reduces the problem to a noncommutative analogue of the arithmetic-geometric mean inequality where $n$ positive numbers are replaced by $n$ positive definite matrices. If this inequality holds for all $n$, then without-replacement sampling indeed outperforms with-replacement sampling. The conjectured Recht-R\'e inequality has so far only been established for $n = 2$ and a special case of $n = 3$. We will show that the Recht-R\'e conjecture is false for general $n$. Our approach relies on the noncommutative Positivstellensatz, which allows us to reduce the conjectured inequality to a semidefinite program and the validity of the conjecture to certain bounds for the optimum values, which we show are false as soon as $n = 5$.