In the opinion written by Justice Ruth Bader Ginsburg, the court said Burt Lancaster, a former police officer in Michigan with a history of mental health issues who was convicted of killing his girlfriend, wasn’t entitled to a new trial, reversing a lower court determination that he should have been allowed to argue his mental illness diminished his guilt.
During his trial, Lancaster asserted a defense of diminished capacity, which, under existing Michigan law, permitted a legally sane defendant to present evidence of mental illness to negate the specific intent necessary to commit a particular crime.
Lancaster was convicted of first-degree murder and a related weapons charge and later got federal habeas relief from these convictions.
By the time of Lancaster’s retrial, the Michigan Supreme Court had rejected the diminished-capacity defense. Even though the killing occurred years before the state Supreme Court decision, the judge at his second trial applied the ruling and disallowed Lancaster’s diminished-capacity defense. Lancaster was convicted again.
On appeal, the 6th U.S. Circuit Court of Appeals held applying the state Supreme Court ruling to an event that occurred years before violated Lancaster’s due process.
Ginsburg said Lancaster could not get habeas relief under the Antiterrorism and Effective Death Penalty Act of 1996 without establishing the “state-court decision he assails ‘was contrary to, or involved an unreasonable application of, clearly established federal law,'” as determined by the Supreme Court.
“We hold that Lancaster’s petition does not meet AEDPA’s requirement and that the United States Court of Appeals for the 6th Circuit erred in granting him federal habeas relief,” the unanimous opinion said in reversing the decision.
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