Metrish v. Lancaster

Federal habeas relief will only be granted if a state court, in rejecting a due process claim, unreasonably applied a clearly established Federal law.

Respondent shot and killed his girlfriend. At trial, Respondent asserted a "diminished capacity" defense, but the jury convicted him of first-degree murder and a related firearm offense. By the time of Respondent's retrial, the Michigan Supreme Court rejected the "diminished capacity" defense in People v. Carpenter, 464 Mich. 223, 627 N. W. 2d 276 (2001). Carpenter was applied at Respondent's retrial and the "diminished capacity" defense was not allowed.

The Michigan Court of Appeals upheld the decision. The Michigan Supreme Court denied review, and Respondent asserted a due process claim in a federal habeas petition. The District Court denied the petition, but the Sixth Circuit reversed and granted federal habeas relief. The United States Supreme Court granted certiorari.

The Court reversed and held that Respondent is not entitled to federal habeas relief on his due process claim because it does not meet the standard set by the Antiterrorism and Effective Death Penalty Act (AEDPA). In a habeas review, the standard set by the AEDPA, relief can only be granted if the state court decision "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). The Court held that applying Carpenter retroactively to Respondent’s case is not an unreasonable use of law.