Metrish v. Lancaster

PETITIONER: Linda Metrish, Warden
RESPONDENT: Burt Landcaster
LOCATION: U.S. Court of Appeals for the Sixth Circuit

DOCKET NO.: 12-547
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 569 US 1781 (2013)
GRANTED: Jan 18, 2013
ARGUED: Apr 24, 2013
DECIDED: May 20, 2013

ADVOCATES:
John J. Bursch - Michigan Solicitor General, for the petitioner
Kenneth M. Mogill - for the respondent

Facts of the case

On April 23, 1993, Burt Lancaster, a former Detroit police officer with a history of mental health problems, shot and killed his girlfriend. He was charged with first-degree murder and possession of a firearm in the commission of a felony. At his trial in state court, Lancaster admitted to the killing but argued he was not guilty by reason of insanity and diminished capacity. The jury convicted Lancaster on both counts.

After exhausting his appeals in state courts, Lancaster filed a petition for a writ of habeas corpus in federal district court and argued that the state had improperly excluded a black juror based on his race. The district court granted the writ of habeas corpus, and Lancaster received a new trial in 2005. At the new trial, Lancaster waived his right to a jury and limited his defense to diminished capacity. Since Lancaster's first trial, the Michigan Supreme Court had held that diminished capacity defense was no longer valid. The trial court held that the Michigan Supreme Court ruling applied retroactively and that Lancaster could not use the diminished capacity defense. The Michigan Court of Appeals and the Michigan Supreme Court declined to hear the case, and Lancaster was again convicted on both counts.

Lancaster filed a petition for a writ of habeas corpus. He argued that the abolition of the diminished capacity defense was a substantive change in the law and that the trial court violated his Fifth and Fourteenth Amendment rights by retroactively applying the change to his case. The district court denied his petition and held that the abolition of the diminished capacity defense was a reasonable change because the defense was not well established under Michigan law. The U.S. Court of Appeals for the Sixth Circuit reversed and held that the retroactive application of the new ruling denied Lancaster his right to due process.

Question

Was the Michigan Supreme Court's abolition of the diminished capacity defense an "unexpected and indefensible" change?

Did the Michigan Court of Appeals err in retroactively applying the change to Lancaster's case?

Media for Metrish v. Lancaster

Audio Transcription for Oral Argument - April 24, 2013 in Metrish v. Lancaster

Audio Transcription for Opinion Announcement - May 20, 2013 in Metrish v. Lancaster

John G. Roberts, Jr.:

Justice Ginsburg has our opinion this morning in case 12-547, Metrich versus Lancaster.

Ruth Bader Ginsburg:

Respondent Burt Lancaster is a former police officer with a long history of severe mental-health problems.

In April 1993, he shot and killed his girlfriend in the parking lot of a shopping-plaza.

Lancaster was convicted in Michigan state court of first-degree murder and a related firearm offense.

At the time of the shooting, the Michigan Court of Appeals, which is Michigan's intermediate appellate court, had repeatedly approved the defense of diminished-capacity.

The defendant invoking that defense would present the evidence of his mental illness, not to establish that he was legally insane, but instead to suggest that he lacked the specific intent, the mens rea, required to find the defendant guilty of the crime with which he was charged. By the time of Lancaster's 2005 trial, however, in a case decided in 2001, People v. Carpenter, the Michigan Supreme Court had rejected the diminished-capacity defense.

Michigan's Legislature, the Michigan Supreme Court held, had foreclosed use of the defense by failing to incorporate it into the state's comprehensive statutory scheme, codified in 1975, governing mental illness defenses.

Based on Carpenter's holding, the judge presiding at Lancaster's trial barred him from asserting a diminished-capacity defense.

The Michigan Court of Appeals affirmed, rejecting Lancaster's argument that the trial court's retroactive application of Carpenter violated due process.

After the Michigan Supreme Court declined review, Lancaster reasserted his due process claim in a federal habeas petition.

The District Court denied the petition, but a divided the panel of the United States Court of Appeals for the Sixth Circuit reversed.

The Michigan high court's decision in Carpenter was unforeseeable, the Sixth Circuit majority concluded, for three reasons: First, as previously mentioned the Michigan Court of Appeals had consistently approved the diminished-capacity defense.

Second, before Carpenter, the Michigan Supreme Court had several times mentioned the defense without casting a shadow of doubt on it.

Finally, the Michigan State Bar had included the defense in its pattern jury instructions.

These considerations persuaded the Sixth Circuit majority that by rejecting Lancaster's due process claim, the Michigan Court of Appeals had unreasonably applied clearly established federal law.

The Sixth Circuit, therefore, ruled that Lancaster was entitled to a new trial at which he could present his diminished-capacity defense.

We granted review and now reverse.

Lancaster's habeas claim is subject to the demanding standards set by the Antiterrorism and Effective Death Penalty Act of 1996.

Under that standard, Lancaster may gain relief only if the state court decision he assails unreasonably applied clearly established federal law as determined by this Court.

Lancaster has not satisfied that exacting standard.

When the judiciary alters a common law doctrine of criminal law, we have held, the Due Process Clause prohibits retroactive application of the alteration only if the rule change is unexpected and indefensible by reference to the law expressed prior to the conduct at issue.

In Carpenter, the Michigan Supreme Court, for the first time, squarely addressed the validity of the diminished-capacity defense.

Rejecting several lower court decisions that had approved the defense Michigan's high court rested its judgment on a reasonable interpretation of controlling statutory language.

This Court has never found a due process violation in circumstances even remotely resembling Lancaster's case.

Fair-minded jurist, no doubt, could conclude that the decision of the Michigan Supreme Court -- the decisions of that Court reached in Carpenter was not unexpected nor was it indefensible.

Lancaster, therefore, is not entitled to federal habeas relief.

The Court's decision is unanimous.

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