Retroactive defense changes
Metrish v. Lancaster
In brief
The Supreme Court overturned the Sixth Circuit’s ruling and denied Lancaster federal relief on this claim.
- Where it stands
- Decided
Decided 9-0 · May 20, 2013 · Opinion by Justice Ginsburg
- What it’s about
- Burt Lancaster argued that applying Michigan’s later elimination of the diminished-capacity defense to his case violated due process.
- Who it affects
- Lancaster cannot get federal relief from his state conviction based on this challenge.
Summary: written with AI from the case record.

What it's about
The Supreme Court overturned the Sixth Circuit and ruled that Lancaster was not entitled to relief from his state conviction in federal court.
Michigan had eliminated the diminished-capacity defense, and Lancaster challenged applying that change to his case.
Question presented
1. Was the Michigan Supreme Court's abolition of the diminished capacity defense an "unexpected and indefensible" change? 2. Did the Michigan Court of Appeals err in retroactively applying the change to Lancaster's case?
What the Court decided
Holding
Lancaster is not entitled to federal habeas relief. 683 F. 3d 740, reversed.
- Result
- Reversed
The Court's reasoning
The Court concluded that applying Michigan’s elimination of the diminished-capacity defense to Lancaster was reasonable, so he was not entitled to federal relief.
The vote
What's next
Lancaster receives no federal relief from his state conviction through this case; the Supreme Court did not overturn the conviction itself.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Case Briefing
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Case data updated: summary, question_presented, generation_metadata
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Audio Recording added: Oral Arguments - Metrish
Opinion added: Metrish
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.