Habeas Corpus — due process

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U.S. Supreme Court

Criminal

Habeas Corpus — -due process

A state court’s retroactive rejection of a diminished-capacity defense does not violate due process.

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hold in Rogers that a newly announced judicial rule may be applied retroactively only if the rule it replaces was an “outdated relic” rarely appearing in a jurisdiction’s case law. 532 U. S., at 462–467.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.

683 F. 3d 740, reversed.

12-547 Metrish v. Lancaster

Ginsburg, J.