People v. Reese
491 Mich. 127
| Mich. | 2012Background
- Defendant Verdell Reese III was charged with second-degree murder and voluntary manslaughter for Johnson’s April 2008 death.
- Trial was a bench proceeding; defense argued self-defense and, alternatively, imperfect self-defense.
- Trial court rejected self-defense as complete and concluded imperfect self-defense applied, reducing murder to manslaughter.
- Court of Appeals vacated the manslaughter conviction, remanding for a new trial on the basis of improper imperfect self-defense application.
- Supreme Court granted leave to decide whether imperfect self-defense exists in Michigan and, if so, its application to the facts.
- Court ultimately held imperfect self-defense does not exist as an independent defense in Michigan law, affirming the manslaughter conviction
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does imperfect self-defense exist as an independent defense in Michigan law? | Prosecution argued the doctrine is recognized and can mitigate murder to manslaughter | Reese argued the doctrine applies where the defendant is initial aggressor | No; imperfect self-defense does not exist as a freestanding defense |
| Was the evidence sufficient to sustain voluntary manslaughter given Reese’s claimed self-defense? | People contends evidence shows malice and causation beyond reasonable doubt | Defense contends insufficient evidence of requisite intent under manslaughter | Yes; evidence supported all elements of voluntary manslaughter beyond a reasonable doubt |
| Was Reese entitled to self-defense as a complete justification for shooting Johnson? | Prosecution contends initial aggressor precludes complete self-defense | Reese contends he acted in self-defense | No; trial court’s finding that Reese was initial aggressor was not clearly erroneous |
Key Cases Cited
- People v Mendoza, 468 Mich 527 (2003) (defines malice and the relation between murder and manslaughter; provocation negates malice)
- People v Riddle, 467 Mich 116 (2002) (necessity and retreat principles; aggressor rules in self-defense context)
- People v Springer, 100 Mich App 418 (1980) (first Michigan adoption of imperfect self-defense doctrine (subject to later developments))
- People v Kemp, 202 Mich App 318 (1993) (cautions against expanding imperfect self-defense beyond initial aggressor inquiry)
- People v Mendoza (dissent referenced), 468 Mich 527 (2003) (context for Mendoza framework; relevance to malice and provocation)