Status of the Diminished Capacity Defense in Michigan

In the case of Metrish v Lancaster, decided in May, 2013, the United States Supreme Court decided that the Michigan Supreme Court was correct when it did not allow Mr. Lancaster to use a diminished capacity defense in his second trial because the defense was determined to be no longer valid by the Michigan Supreme Court in the time between his first and second trial.

Diminished Capacity Defense Case

Diminished capacity is short of a claim of actual insanity. It states that a person could not have formed the intent to commit the crime because of some mental defect at the time of the crime. The defense was available to Mr. Lancaster at his first trial. It was not successful and he was convicted of first degree murder. The case was sent back for another trial on unrelated grounds.

Since Lancaster’s first trial, the Michigan Supreme Court held that the diminished capacity was no longer valid. The trial court held that the Michigan Supreme Court decision applied retroactively and Lancaster could not use the defense in his second trial. The Michigan Court of Appeals and Michigan Supreme Court declined to hear the appeal. Mr. Lancaster went to the federal system. The federal district court agreed with the trial court holding that the abolition of the diminished capacity defense was a reasonable change because it was not well established under Michigan law. The 6th Circuit Court of Appeals reversed the federal district court holding the retroactive application denied Mr. Lancaster of his due process rights
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The issues presented to the United States Supreme Court were whether the Michigan Supreme Court’s abolishment of the diminished capacity defense was an unexpected and indefensible change and did the Michigan Court of Appeals make a mistake in retroactively applying the change to Lancaster’s case. The United States Supreme Court said no to both issues.

The Court held that the Michigan Supreme Court ruling eliminating the diminished capacity defense was reasonable as it had limited applicability in Michigan law and was not included in Michigan’s statutory scheme. Also, that retroactive application did not violate due process because it represented a foreseeable interpretation of the statute by the Michigan Supreme Court.

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