People v. Ramsey case brief

People v. Ramsey case brief summary
375 N.W.2d 297 (1985)

CASE SYNOPSIS

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 Michigan Court of Appeals affirmed the convictions. The defendants appealed.

ARGUMENT
Both defendants contended that the guilty, but mentally ill verdict denied them the due process of law guaranteed by the Fourteenth Amendment.

DISCUSSION

• The court concluded that Mich. Comp. Laws § 768.36; Mich. Stat. Ann. § 28.1059 was constitutional because it did not violate principles of fairness. 
• The court also concluded that 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 court found that the inclusion of the guilty, but mentally ill verdict was not so confusing to the jury that it denied defendants a fair trial. 
• The court also rejected the assertions of the defendant who was convicted of murder that a finding of mental illness negated malice aforethought as a matter of law and that a trial court must, in its findings of fact following a bench trial, affirmatively state that the mental illness did not negate the necessary intent for second-degree murder.

CONCLUSION
The court affirmed the convictions.

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