Metrish v. Lancaster

*354 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…