People v Madison
Key claim: The Michigan Supreme Court overruled People v Carpenter and held that MCL 768.21a does not bar defendants from presenting diminished-capacity evidence to contest the mens rea element of specific-intent crimes.
Abstract
Michigan Supreme Court opinion decided 2026-07-31. Michigan Supreme Court Lansing, Michigan
Syllabus Chief Justice: Justices: Megan K. Cavanagh Brian K. Zahra Richard H. Bernstein Elizabeth M. Welch Kyra H. Bolden Kimberly A. Thomas Noah P. Hood
This syllabus constitutes no part of the opinion of the Court but has been Reporter of Decisions: prepared by the Reporter of Decisions for the convenience of the reader. Kimberly K. Muschong
PEOPLE v MADISON
Docket No. 167120. Argued on application for leave to appeal October 9, 2025. Decided
July 31, 2026.
Cinecca D. Madison, who was 19 years old when he allegedly shot two people, was charged
with open murder, MCL 750.316, assault with intent to commit murder, MCL 750.83, and two
counts of felony-firearm, MCL 750.227b. Defendant moved for a competency evaluation and an
evaluation of his criminal responsibility in the Ottawa Circuit Court; the court entered orders
referring defendant to the Center for Forensic Psychiatry, where he was evaluated by Dr. Michele
Hill, who concluded that defendant was competent to stand trial. Dr. Hill noted that, while
defendant had not been medicated at the time of the shooting, he had since been taking a prescribed
antipsychotic administered by the jail. With regard to criminal responsibility, Dr. Hill initially was
not sure whether defendant suffered from any mental illness, but she later learned that,
approximately 10 months before the shooting, defendant had been the subject of mental-illness
proceedings. The Ottawa Probate Court had issued a mental-health pick-up order for defendant
shortly after he received treatment for paranoia and hallucinations, and Community Mental Health
of Ottawa County had diagnosed defendant with schizophreniform disorder, a precursor diagnosis
to schizophrenia. Nevertheless, Dr. Hill concluded that defendant was not legally insane at the
time of the alleged crime. One of defendant’s psychological experts opined that defendant was
not legally insane at the time of the alleged crime but that defendant’s mental illness affected his
behavior and actions.
Defendant moved to present evidence and submit jury instructions regarding his
diminished capacity, arguing that his diminished capacity negated the specific-intent element of
the charged crimes. The court, Karen J. Miedema, J., denied defendant’s motion on the basis that
People v Carpenter, 464 Mich 223 (2001), held that evidence of mental incapacity short of insanity
cannot be used to avoid or reduce criminal responsibility by negating specific intent. Defendant
sought leave to appeal, and the Court of Appeals, REDFORD, P.J., and CAVANAGH and YATES, JJ.,
denied leave to appeal. Defendant sought interlocutory leave to appeal in the Supreme Court,
challenging the continued viability of Carpenter and seeking to present evidence of his alleged
diminished capacity at trial. The Supreme Court stayed the trial court proceedings and ordered
and heard oral argument on the application. 515 Mich 1016 (2024).
In an opinion by Justice BERNSTEIN, joined by Chief Justice CAVANAGH and Justices WELCH, BOLDEN, THOMAS, and HOOD, the Supreme Court, in lieu of granting leave to appeal, held:
1. The Carpenter Court erred by ruling that the legal-insanity statute, MCL 768.21a,
foreclosed the presentation of diminished-capacity evidence to contest the mens rea element of a charged specific-intent crime. The Carpenter Court expended little effort on interpreting the language of MCL 768.21a, which on its face addresses only the affirmative defense available to a legally insane defendant. There is no language in the statute directed at the concept of diminished capacity. A diminished-capacity argument is distinct from the insanity defense. The insanity defense is an affirmative defense that admits guilt but seeks to excuse it without reference to any individual elements of the crime. In contrast, the purpose of diminished-capacity evidence is aimed at negating specific intent; this approach does not admit the crime and seek to then excuse or justify it but instead challenges the prosecution’s case by questioning whether a defendant had the requisite mens rea at the time of the crime. Because diminished capacity is necessarily distinct from the affirmative defense of legal insanity, the Legislature’s codification of the legal-insanity defense has no bearing on the admissibility of diminished-capacity evidence. The statement in MCL 768.21a(1) that “[m]ental illness or having an intellectual disability does not otherwise constitute a defense of legal insanity” means precisely what it says; although evidence of a defendant’s diminished capacity because of mental illness or intellectual disability cannot constitute an affirmative defense of legal insanity, the statute simply does not state or imply anything about the availability of diminished-capacity evidence to negate a specific element of a crime. The Carpenter Court’s erroneous conclusion that the Legislature had created a comprehensive statutory scheme governing any defense rooted in mental illness or intellectual disability was contrary to the plain language of MCL 768.21a and the statute allowing a defendant to be found guilty but mentally ill, MCL 768.36; further, it improperly used the Legislature’s silence on the use of evidence of diminished capacity outside of legal insanity to overturn decades of common law.
2. Principles of stare decisis weigh in favor of overruling Carpenter. Whether a case was
wrongly decided is not, in itself, determinative of whether it should be overruled. In determining whether the decision should be overruled, a court reviews whether the decision defies practical workability, whether reliance interests would work an undue hardship were the decision to be overruled, and whether changes in the law or facts no longer justify the decision. The court may also consider whether the prior decision was an abrupt and largely unexplained departure from precedent and whether upholding the rule is likely to result in serious detriment prejudicial to public interests. Regarding practical workability, while Carpenter’s all-or-nothing approach is straightforward to apply, this factor is of little weight in comparison to the import of safeguarding the ability of criminal defendants to present a defense that should be available and that was otherwise available for at least 30 years before Carpenter. Next, reliance interests do not weigh in favor of retaining Carpenter. Overruling Carpenter will lead to a change in evidence that some defendants seek to raise in the context of their own individual trials, but this will not create a dislocation of the trial process. Fact-finders and trial court judges are well equipped to adjust to the renewed availability of the diminished-capacity defense, and evidentiary rules will guide the admission of mental-health evidence in this context as they would in any other. The most serious concern regarding reliance interests is how overruling Carpenter will impact court operations in the aggregate, but e
Why this matters
The Michigan Supreme Court overruled People v Carpenter and held that MCL 768.21a does not bar defendants from presenting diminished-capacity evidence to contest the mens rea element of specific-intent crimes.