A fair trial is a right guaranteed by the Due Process Clause of the U.S. Const. amend. XIV.
In two separate cases, defendants were found guilty, but mentally ill. One was convicted of second-degree murder and the other was convicted of armed robbery and assault with intent to commit robbery while armed. Both challenged the constitutionality of Mich. Comp. Laws § 768.36; Mich. Stat. Ann. § 28.1059, which permitted the guilty, but mentally ill verdict. The appellate court affirmed the convictions. The defendants appealed, and the state supreme court affirmed the convictions.
Did the guilty, but mentally ill verdict, permitted under Mich. Comp. Laws § 768.36; Mich. Stat. Ann. § 28.1059, deny defendants of the due process of law guaranteed by the Fourteenth Amendment?
The verdict did not deflect a jury's attention from the issues of guilt or innocence by adding an irrelevant verdict which brought the risk of impermissible jury compromise. The Legislature had created a clear distinction between mental illness and insanity, so that it could not be said that such distinctions denied defendants the right to a fair trial. A finding of mental illness did not negate malice aforethought as a matter of law. Mich. Comp. Laws § 768.36; Mich. Stat. Ann. § 28.1059 was constitutional because it did not violate principles of fairness.