People of Michigan v. Menayetta Michell Yeager, 999 N.W.2d 490

Yeager and her boyfriend Brooks had a violent confrontation after she announced a breakup: Brooks struck her with a gun, pulled her out of her van, attempted to run her down with the van, and later threatened to kill her and a neighbor who assisted her.
At a gas station during a continued confrontation, Yeager fired multiple shots; Brooks later died. Police recovered 17 shell casings; Yeager surrendered the next day.
Yeager was tried and convicted by a jury of first-degree premeditated murder and felony-firearm; the jury had been instructed only on first- and second-degree murder (no manslaughter instruction).
On appeal the case was remanded for a Ginther hearing limited to whether trial counsel was ineffective for not requesting a voluntary manslaughter instruction; the trial court granted a new trial, but the Court of Appeals reversed relying on People v. Raper.
The Michigan Supreme Court reversed the Court of Appeals: it held trial counsel’s failure to request a voluntary manslaughter instruction was objectively unreasonable and that the omission was prejudicial, entitling Yeager to a new trial (majority). Two justices and the Chief Justice dissented on prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was trial counsel’s failure to request a voluntary manslaughter instruction objectively unreasonable?	Counsel’s choice was a reasonable strategic decision tied to a self-defense theory and belief Yeager had time to cool off.	Counsel misunderstood the law: self-defense and voluntary manslaughter are not mutually exclusive; manslaughter instruction was legally available and supported by the evidence.	Majority: Yes—counsel’s explanation reflected a legal error and the omission was objectively unreasonable.
Did the omission prejudice Yeager (reasonable probability of different outcome)?	No—because the jury convicted of first-degree murder (rejecting second-degree), the error was harmless; Raper supports treating such omissions as nonprejudicial.	Yes—the jury never had the legally distinct manslaughter option addressing provocation/heat of passion; a reasonable jury could have convicted of voluntary manslaughter.	Majority: Yes—prejudice shown; failure to instruct undermined confidence in outcome and warrants a new trial. (Dissent would find no prejudice.)

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong federal ineffective-assistance standard: deficient performance and prejudice)
People v. Mendoza, 468 Mich 527 (2003) (manslaughter is a necessarily included lesser offense of murder; instruction required if rationally supported)
People v. Beach, 429 Mich 450 (1988) (framework for assessing harmlessness when a lesser-offense instruction is omitted)
Maher v. People, 10 Mich 212 (1862) (classic formulation of voluntary manslaughter: killing in heat of passion from adequate provocation)
People v. Cornell, 466 Mich 335 (2002) (lesser-included instruction appropriate when charged offense involves a disputed element not in the lesser and a rational view of the evidence supports it)
People v. Raper, 222 Mich App 475 (1997) (COA decision treating omission of manslaughter instruction as harmless where jury convicted first-degree over second-degree; majority here rejects a bright-line application of that rule)