Lancaster v. Metrish, No. 10-2112 (6th Cir. 2012)
Annotate this CaseIn 1993, Lancaster, a former police officer with a long history of mental illness, shot his girlfriend and was charged by the state of Michigan with first-degree murder and with possession of a firearm in the commission of a felony. At his 1994 jury trial, he was convicted on both counts despite his asserted defenses of insanity and diminished capacity. The judgment was overturned, however, due to a Batson violation. When Lancaster was retried in 2005, he opted to be tried without a jury. Lancaster had planned to limit his defense to diminished capacity. But the trial court prohibited Lancaster from asserting the defense because, in the interim between his two trials, the Michigan Supreme Court had abolished the diminished-capacity defense (Carpenter decision). Lancaster was convicted and sentenced to life plus two years in prison. In his petition for a writ of habeas corpus, Lancaster claimed that his right to due process was violated by the state court’s retroactive application of Carpenter. The district court denied his petition. The Sixth Circuit reversed, granting the petition unless the state commences a new trial within 180 days in which Lancaster is permitted to assert the defense of diminished capacity.
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