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Supreme Court rules defendant not entitled to federal habeas relief

The US Supreme Court [official website] ruled [opinion, PDF] unanimously Monday in Metrish v. Lancaster [SCOTUSblog backgrounder] that respondent Burt Lancaster is not entitled to federal habeas relief. Lancaster was convicted of murder in a Michigan state court. At the time the crime was committed, the Michigan appeals court recognized "diminished capacity" as a defense negating the mens rea element of first-degree murder, but by the time he was tried and convicted, the Michigan Supreme Court had rejected this defense. Lancaster sought federal habeas relief for a violation of due process. In an opinion authored by Justice Ruth Bader Ginsburg, the Supreme Court rejected his claim:

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." ... Lancaster therefore is not entitled to federal habeas relief on his due process claim.
The judgment [opinion] of the US Court of Appeals for the Sixth Circuit was reversed.

At oral argument [JURIST report] in April the Michigan solicitor general (SG) argued that under Harrington v. Richter [opinion; JURIST report], "a federal court may only overturn a State court conviction that is such an erroneous misapplication of this court's clearly established precedent as to be beyond any possibility of fair-minded disagreement. That is, an extreme malfunction." In this case, the SG suggested, the state judge simple exercised fair-minded discretion to apply the statute retroactively. The attorney for Lancaster argued that his client had been treated in a fundamentally unfair manner: that his re-trial was not held quickly enough, that the Michigan Supreme Court abolished diminished capacity based on a statute that does not clearly abolish it, and that the Michigan Supreme Court retroactively applied the abolition to Lancaster. Justice Antonin Scalia questioned if Lancaster had been allowed to bring the defense in a timely fashion, if the Supreme Court wouldn't have just struck it then, and if anyone had ever mitigated their charges in Michigan based on diminished capacity.

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