SCOTUS unanimously reverses habeas win for defendant based on state elimination of "diminished capacity" defense

Only a matter of weeks after it was argued, the Supreme Court this morning unanimously decided that the Sixth Circuit got a habeas issue wrong in Metrish v. Lancaster, No. 12-547 (S. Ct. May 20, 2013) (available here). Here is the start of the SCOTUS opinion, per Justice Ginsburg:

Burt Lancaster was convicted in Michigan state court of first-degree murder and a related firearm offense.  At the time the crime was committed, Michigan’s intermediate appellate court had repeatedly recognized “diminished capacity” as a defense negating the mens rea element of first-degree murder.  By the time of Lancaster’s trial and conviction, however, the Michigan Supreme Court in People v. Carpenter, 464 Mich. 223, 627 N.W. 2d 276 (2001), had rejected the defense.  Lancaster asserts that retroactive application of the Michigan Supreme Court’s decision in Carpenter denied him due process of law.  On habeas review, a federal court must assess a claim for relief under the demanding standard set by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA).   Under that standard, Lancaster may gain relief only if the state-court decision he assails “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by [this] Court.” 28 U.S.C. § 2254(d)(1).  We hold that Lancaster’s petition does not meet AEDPA’s requirement and that the United States Court of Appeals for the Sixth Circuit erred in granting him federal habeas relief.

Absent something remarkable in the full opinion, I suspect it may prove to be more interesting (or at least more fun) to try to make jokes about the defendant's name in this case rather than to debate the ruling's enduring significance.

Lancaster is the only criminal justice ruling from the Supreme Court today, and I surmise from SCOTUSblog that the next decision day for the Court will be next Tuesday.  I am hopeful (but not optimistic) that the long holiday weekend will give the Justices a chance to finish off at least some of the notable criminal justices cases that we argued way back in January (Alleyne and Deschamps) and February (King and Peugh).  I am also I am hopeful (and a bit more optimistic) that the long holiday weekend will give me a chance to speculate about who may be authoring these opinions and why the are taking so long.