People v. Ramsey

422 Mich. 500, 375 N.W.2d 297 (1985)

 

RULE:

A fair trial is a right guaranteed by the Due Process Clause of the U.S. Const. amend. XIV.

FACTS:

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.

ISSUE:

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?

ANSWER:

No.

CONCLUSION:

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.

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