Metrish v. Lancaster

Background

Burt Lancaster, a former police officer, was convicted in Michigan for a 1993 murder. At his first trial he raised insanity and a diminished-capacity defense but was convicted. After a federal court ordered a new trial for a separate juror-bias error, Michigan’s highest court had already ruled in 2001 that the diminished-capacity defense was not available under Michigan law, and the trial judge at Lancaster’s retrial excluded that defense. Lancaster lost his state appeals and then sought federal habeas relief, which the Sixth Circuit granted before the Supreme Court took the case.

Reasoning

The central question was whether applying Michigan’s 2001 ruling retroactively to Lancaster violated due process and whether a federal court could overturn the state court under the strict federal habeas standard in AEDPA. The Supreme Court compared earlier decisions about unfair retroactive judicial changes and concluded that Michigan’s high court had interpreted its own statute reasonably and did not unexpectedly expand criminal liability in the way that violates due process. Because federal habeas relief requires showing a state court unreasonably applied clearly established Supreme Court law, the Court held the Sixth Circuit erred and reversed.

Real world impact

The decision leaves Michigan’s rejection of the diminished-capacity defense in place for cases like Lancaster’s and narrows grounds for federal habeas relief under AEDPA. Practically, some defendants charged before the 2001 decision may be unable to present diminished-capacity evidence at retrial, and federal courts must defer to reasonable state-court interpretations unless they are clearly unreasonable.

Dissents or concurrances

A dissenting judge in the Sixth Circuit had thought the defense’s elimination was unforeseeable; the Supreme Court found that view not enough to grant habeas relief.