Michigan v. Reese

The Supreme Court granted the prosecution’s application for leave to appeal to resolve whether Michigan law recognizes the doctrine of "imperfect self-defense" as an independent theory that automatically mitigates criminal liability for a homicide from murder to voluntary manslaughter when a defendant acts as the initial aggressor and then claims that the victim’s response necessitated the use of force. The Court held that the doctrine does not exist in Michigan law as a freestanding defense mitigating murder to voluntary manslaughter, although the Court recognized that factual circumstances that have been characterized as imperfect self-defense may negate the malice element of second-degree murder. When analyzing the elements of manslaughter in light of defendant’s self-defense claim, the Court concluded that the Court of Appeals erred in its ruling on the sufficiency of the prosecution’s evidence to sustain Defendant Verdell Reese, III's manslaughter conviction. Therefore, the Court reversed in part the Court of Appeals’ judgment, affirmed the trial court’s verdict of manslaughter, and remanded this case to the Court of Appeals for further consideration of Defendant’s remaining issue on appeal. View "Michigan v. Reese" on Justia Law