Metrish v. Lancaster
Receive FREE Daily Opinion Summaries by Email
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321 .
SUPREME COURT OF THE UNITED STATES
METRISH, WARDEN v. LANCASTER
certiorari to the united states court of appeals for the sixth circuit
No. 12–547. Argued April 24, 2013—Decided May 20, 2013
On April 23, 1993, respondent Burt Lancaster, a former police officer with a long history of severe mental-health problems, shot and killed his girlfriend. At his 1994 jury trial in Michigan state court, Lancaster asserted a defense of diminished capacity. Under then-prevailing Michigan Court of Appeals precedent, the diminished-capacity defense permitted a legally sane defendant to present evidence of mental illness to negate the specific intent required to commit a particular crime. Apparently unpersuaded by Lancaster’s defense, the jury convicted him of first-degree murder and a related firearm offense. Lancaster, however, later obtained federal habeas relief from these convictions.
By the time of Lancaster’s retrial, the Michigan Supreme Court had rejected the diminished-capacity defense in its 2001 decision in Carpenter. Although the murder with which Lancaster was charged occurred several years before Carpenter was decided, the judge at his second trial applied Carpenter and therefore disallowed renewal of his diminished-capacity defense. Lancaster was again convicted. Affirming, the Michigan Court of Appeals rejected Lancaster’s argument that the trial court’s retroactive application of Carpenter vio- lated due process.
Lancaster reasserted his due process claim in a federal habeas petition. The District Court denied the petition, but the Sixth Circuit reversed. Concluding that the Michigan Supreme Court’s 2001 rejection of the diminished-capacity defense was unforeseeable in April 1993, when Lancaster killed his girlfriend, the Sixth Circuit held that, by rejecting Lancaster’s due process claim, the Michigan Court of Appeals had unreasonably applied clearly established federal law.
Held: Lancaster is not entitled to federal habeas relief. Pp. 4–15.
(a) Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), Lancaster may obtain federal habeas relief only if the Michigan Court of Appeals, in rejecting his due process claim, unreasonably applied “clearly established Federal law, as determined by [this] Court.” 28 U. S. C. §2254(d)(1). This standard is “difficult to meet”: Lancaster must show that the Michigan Court of Appeals’ decision rested on “an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement.” Harrington v. Richter, 562 U. S. ___, ___. To determine whether Lancaster has satisfied that demanding standard, the Court first considers two key decisions: Bouie v. City of Columbia, 378 U. S. 347 , and Rogers v. Tennessee, 532 U. S. 451 . It then considers whether the Michigan Court of Appeals’ decision qualifies as an unreasonable application of those decisions to Lancaster’s case. Pp. 4–5.
(b) Bouie concerned African-American petitioners who had refused to leave a South Carolina drug store’s whites-only restaurant area after entering without notice that the store’s policy barred their entry. They were convicted under a South Carolina trespass statute pro- hibiting “ ‘entry upon the lands of another . . . after notice from the owner or tenant prohibiting such entry.’ ” 378 U. S., at 349–350. The South Carolina Supreme Court based its affirmance of the petitioners’ convictions on its prior decision in Mitchell, where the court held that the trespass statute reached both unauthorized entries and “the act of remaining on the premises of another after receiving notice to leave.” 378 U. S., at 350. Mitchell, however, was rendered 21 months after the petitioners’ arrest. This Court held that the Due Process Clause prohibited Mitchell’s retroactive application to the Bouie petitioners, stressing that Mitchell’s interpretation of the state trespass statute was “clearly at variance with the statutory language” and “ha[d] not the slightest support in prior South Carolina decisions.” 378 U. S., at 356.
In Rogers, the petitioner contested the Tennessee Supreme Court’s retroactive abolition of the common-law “year and a day rule,” which barred a murder conviction “unless [the] victim had died by the defendant’s act within a year and a day of the act.” 532 U. S., at 453. This Court found no due process violation. “[J]udicial alteration of a common law doctrine of criminal law,” the Court held, “violates the principle of fair warning, and hence must not be given retroactive effect, only where [the alteration] is ‘unexpected and indefensible by reference to the law which had been expressed prior to the conduct in issue.’ ” Id., at 462. Judged by this standard, the retroactive abolition of the year and a day rule encountered no constitutional impediment. The rule was “widely viewed as an outdated relic of the common law,” had been routinely rejected by modern courts and legislators, and had been mentioned in reported Tennessee decisions “only three times, and each time in dicta.” Id., at 462–464. Pp. 6–8.
(c) The Michigan Court of Appeals’ rejection of Lancaster’s due process claim does not represent an unreasonable application of the law this Court declared in Bouie and Rogers. Pp. 8–15.
(1) The Michigan Court of Appeals first recognized the diminished-capacity defense in 1973. Two years later, the Michigan Legislature prescribed comprehensive requirements for defenses based on mental illness or retardation. In 1978, the Michigan Court of Appeals ruled that the diminished-capacity defense fit within the codified definition of insanity. The Michigan Supreme Court’s 2001 decision in Carpenter, however, rejected that position, holding that the diminished-capacity defense was not encompassed within the Michigan Legislature’s comprehensive scheme for mental-illness defenses and thus could not be invoked by criminal defendants. Pp. 8–12.
(2) In light of this Court’s precedent and the history of Michigan’s diminished-capacity defense, the Michigan Court of Appeals’ decision applying Carpenter retroactively is not “an unreasonable application of . . . clearly established [f]ederal law.” 28 U. S. C. §2254(d)(1). This case is a far cry from Bouie, where the South Carolina Supreme Court unexpectedly expanded “narrow and precise statutory language” that, as written, did not reach the petitioners’ conduct. 378 U. S., at 352. In Carpenter, by contrast, the Michigan Supreme Court rejected a diminished-capacity defense that the court reasonably found to have no home in a comprehensive, on-point statute enacted by the Michigan Legislature. Although Lancaster’s due process claim is arguably less weak than the due process claim rejected in Rogers, the Court did not hold in Rogers that a newly announced judicial rule may be applied retroactively only if the rule it replaces was an “outdated relic” rarely appearing in a jurisdiction’s case law. 532 U. S., at 462–467. Distinguishing Rogers thus does little to bolster Lancaster’s argument that the Michigan Court of Appeals’ decision unreasonably applied clearly established federal law. This Court has never found a due process violation in circumstances remotely resembling Lancaster’s case—i.e., where a state supreme court, squarely addressing a particular issue for the first time, rejected a consistent line of lower court decisions based on the supreme court’s reasonable interpretation of the language of a controlling statute. Fairminded jurists could conclude that a state supreme court decision of that order is not “ ‘unexpected and indefensible by reference to [existing] law.’ ” Id., at 462. Pp. 12–15.
683 F. 3d 740, reversed.
Ginsburg, J., delivered the opinion for a unanimous Court.