Linda Metrish v. Burt Lancaster.

Summary

The Supreme Court reversed the Sixth Circuit's grant of federal habeas relief to Burt Lancaster, who argued that Michigan's retroactive application of People v. Carpenter — which abolished the diminished-capacity defense after his 1993 crime — denied him due process. Applying AEDPA's demanding § 2254(d)(1) standard, the Court held the Michigan Court of Appeals' rejection of the due process claim was not an unreasonable application of clearly established federal law: unlike Bouie, Carpenter disapproved lower-court precedent resting on a reasonable reading of a comprehensive statute rather than expanding narrow statutory language, and the Court has never found a due process violation where a state supreme court, addressing an issue for the first time, rejected a consistent line of lower-court decisions based on a reasonable statutory interpretation. Although Lancaster's position was arguably stronger than the losing argument in Rogers v. Tennessee, distinguishing a case in which the Court rejected a similar claim does not establish entitlement to relief.