20 May 2013

Law in Plain English: Metrish v. Lancaster

This is one in a series of posts designed to describe court decisions in plain English. For more detail and background on the legal issues, see the link to the case below. For similar posts, click here.

Metrish v. Lancaster

Lancaster shot and killed his girlfriend in 1993. At trial in 1994, he claimed diminished capacity, but the jury convicted him. He later obtained federal habeas relief and a new trial. By the time of his second trial, the Michigan Supreme Court had subsequently rejected the diminished capacity defense. The judge disallowed this defense, and Lancaster was again convicted. He filed another federal habeas petition which the District Court denied. The Sixth Circuit reversed, ruling that the Michigan trial court had unreasonably applied clearly established federal law. The questions before the Court were: (1) Whether the Michigan Supreme Court’s recognition that a state statute abolished the long-maligned diminished-capacity defense was an “unexpected and indefensible” change in a common-law doctrine of criminal law; and (2) whether the Michigan Court of Appeals’ retroactive application of the Michigan Supreme Court’s decision was “so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement” so as to justify habeas relief. In a unanimous decision, the Supreme Court ruled that the Michigan Court of Appeals’ rejection of Lancaster’s due process claim does not represent an unreasonable application of the law. As a result, Lancaster was not entitled to federal habeas relief. The practical impact of this decision is that where a state supreme court, squarely addressing a particular issue for the first time, rejects a consistent line of lower court decisions based on the supreme court’s reasonable interpretation of the language of a controlling statute, the Supreme Court will not find a due process violation.
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