Metrish v. Lancaster
133 S. Ct. 1781
SCOTUS2013Background
- Lancaster killed his girlfriend in 1993 and initially faced diminished-capacity defenses in Michigan.
- Michigan courts allowed diminished-capacity evidence before Carpenter (2001) but later rejected it under Carpenter.
- Lancaster was retried in 2005 and convicted despite Carpenter’s retroactive application being disputed.
- Michigan Supreme Court decided Carpenter limited diminished-capacity to not fit within the comprehensive mental-illness scheme.
- Lancaster asserted due process claims on retroactive Carpenter application; District Court denied, Sixth Circuit granted relief.
- Supreme Court held Lancaster not entitled to habeas relief; the Michigan court’s decision was not an unreasonable application of clearly established law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Carpenter retroactively applying to Lancaster due process | Lancaster asserts due process violated by retroactive Carpenter. | Michigan court reasonably applied Carpenter retroactively. | Not an unreasonable application; no due process violation. |
| AEDPA standard application to state court decision | Lancaster must show unreasonable application of clearly established federal law. | State court decision reasonably applied Supreme Court precedent under AEDPA. | Not met; no unreasonable application found. |
| Bouie and Rogers framework governing retroactivity | Michigan’s retroactive Carpenter conflicts with Bouie/Rogers due process concerns. | Michigan’s retroactive decision is distinguishable and not contrary to clearly established law. | Michigan decision not an unreasonable application of Bouie/Rogers. |
Key Cases Cited
- Bouie v. City of Columbia, 378 U. S. 347 (1964) (due process limits on retroactive judicial expansion of statutes)
- Rogers v. Tennessee, 532 U. S. 451 (2001) (retroactivity limits for judicial rulings; fair warning standard)
- Harrington v. Richter, 562 U. S. _ (2011) (clear error standard for AEDPA deference (slip op.))
- Carpenter, 464 Mich. 223 (2001) (diminished-capacity defense rejected as not within statutory scheme)
- Lancaster v. Adams, 324 F.3d 423 (6th Cir. 2003) (previous habeas relief on race-based juror challenge)
- Lynch, 47 Mich. App. 8 (1973) (early recognition of diminished-capacity defense in Michigan)