In the case of Linda Metrish, Warden v. Burt Lancaster (2012), the U.S. Supreme Court ruled that a Michigan state prisoner was not entitled to federal habeas corpus relief on his claim that he had been denied due process when the Michigan courts retroactively applied a judicially announced change in law to deny him an insanity defense at his retrial for murder. The court held that it was not "clearly established Federal law" at the time of Lancaster's trial and appeal that such a retroactive application would violate due process rights under circumstances where all other elements necessary for invocation of this constitutional protection were present. This decision reaffirmed states' authority over their own criminal justice systems while also underscoring federal courts' limited role in reviewing state-court decisions.

In the dissenting opinion for Linda Metrish, Warden, Petitioner v. Burt Lancaster (2012), Justice Alito argued that the majority's decision to uphold a Michigan Supreme Court ruling retroactively eliminating diminished capacity as a defense was incorrect. He contended that this violated due process rights by changing established law in an unpredictable manner and applying it retrospectively to criminal defendants who relied on existing legal standards at the time of their trials. The justice believed that such changes should not be applied retroactively unless they are foreseeable based on previous court decisions or legislative actions. In his view, there was no clear indication from either source suggesting Michigan would eliminate diminished capacity as a defense when Lancaster committed his crime and went to trial.