People v. Mitchell, 301 Mich. App. 282

Defendant appeals after conviction for second-degree murder and carrying a weapon with unlawful intent.
Trial established ongoing harassment by defendant toward the victim over a $5 debt; threats and banging on doors.
Victim’s death occurred January 16, 2011; autopsy showed head/neck injuries and possible bat blows.
Defendant claimed self-defense; admitted altercation and had a swollen hand and bruising.
A baseball bat and a knife were found at the victim’s apartment; victim kept a bat at that location.
Trial court denied a requested voluntary manslaughter instruction; jury found defendant guilty of the charged offenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntary manslaughter instruction required?	Hoekstra: evidence supported provocation; instruction should have been given.	Hoekstra: insufficient provocation; but defendant sought instruction.	Yes; instruction required; error.
Go es armed interpretation of MCL 750.226—did evidence prove you go armed?	Hoekstra: statute requires leaving a location with a qualifying weapon.	Presents that weapons present at scene cannot satisfy goes armed.	Insufficient evidence; reversed as to weapon conviction.
Sufficiency of evidence for MCL 750.226 after interpretation?	Hoekstra: evidence supports goes armed.	No evidence defendant left with weapon; cannot convict.	Insufficient evidence; acquittal required.
Imperfect self-defense doctrine raised?	—	Doctrine does not exist in Michigan law.	Argument lacks merit; doctrine not recognized.

People v Lukity, 460 Mich 484 (1999) (standard for outcome-determinative error; Lukity applied)
People v Mendoza, 468 Mich 527 (2003) (heat-of-passion standard for voluntary manslaughter)
People v Reese, 491 Mich 127 (2012) (provocation standard; confirms lack of perfect self-defense)
People v Cornell, 466 Mich 335 (2002) (proportional impact of ungiven requested instruction)
People v Peltola, 489 Mich 174 (2011) (goes armed interpretation; statutory intent)