Michigan's highest court has torn down a 25-year-old rule that kept juries from hearing about a defendant's mental illness unless that person was found legally insane, and the case that did it traces back to a June 2022 shooting near Hope College in Holland that left one teenager dead and another critically wounded. The Michigan Supreme Court's 6-1 decision in People v. Madison means defense attorneys can now use psychiatric evidence to argue a defendant lacked the specific intent required for certain crimes, even without meeting the far higher bar of an insanity defense.
The ruling, issued July 31, centers on Daquan Madison, who was 19 years old when he allegedly fired a gun at two companions while they were riding bicycles near Holland College, killing 19-year-old Antory Burrell and critically wounding 18-year-old Demontae Knight, according to The Oakland Press. Knight survived by playing dead after being shot, as reported by Ottawa News Network, citing reporting from The Holland Sentinel. Madison now awaits trial in Ottawa County Circuit Court, located in Grand Haven, on charges of open homicide, assault with intent to murder, and felony firearms.
Mental health experts who evaluated Madison determined he is schizophrenic but was not legally insane at the time of the shooting. Court records cited in 2025 psychological filings indicate Madison suffered from untreated schizophreniform disorder during the incident, experiencing paranoid delusions, hearing what filings described as evil whispers, and believing he saw the victim clutching a weapon immediately before firing, per the Ottawa News Network account. He had been prescribed antipsychotic medication while jailed awaiting trial but was unmedicated at the time of the shooting.
A 25-Year Rule Built on a Saginaw Home Invasion
The trial judge in Madison's case had prohibited his defense from presenting psychological-expert evidence, following a rule that had stood since 2001. That earlier precedent, People v. Carpenter, originated from a July 1995 incident in Saginaw in which defendant James A. Carpenter crashed through a window into a home and fired shots, later claiming organic brain damage and hallucinatory voices, according to background compiled by FindLaw. Carpenter was convicted of first-degree home invasion after the trial court rejected his diminished capacity defense, and the state supreme court used the case to bar such defenses statewide for the next quarter-century.
The U.S. Supreme Court weighed in on Michigan's approach in May 2013, unanimously ruling in Metrish v. Lancaster that state courts did not violate federal due process by retroactively applying Carpenter to block a former Detroit police officer with severe mental illness from raising a diminished capacity defense in a murder retrial, per Justia. That ruling affirmed that states have broad constitutional authority to shape their own criminal responsibility standards, even as critics argued Michigan's all-or-nothing approach ignored established psychiatric science.
Why the Court Says It Got It Wrong
In the majority opinion, Justice Richard Bernstein wrote that the court erred in 2001 by misinterpreting MCL 768.21a, clarifying that Michigan's legal-insanity statute was created as an affirmative defense rather than a blanket ban on mental-health evidence used to challenge specific intent, according to the Detroit Legal News. Bernstein noted that diminished capacity and legal insanity are two distinct legal concepts the earlier court had conflated. Justice Brian Zahra dissented from the decision.
The American Psychological Association had filed a June 2025 amicus brief presenting empirical research showing that symptoms of severe mental illness, including perceptual disturbances and information-processing deficits, can impair a defendant's ability to form specific criminal intent even when that person is not legally insane. The brief argued that prohibiting such evidence ignored well-established psychiatric research. Under the new ruling, a specific intent crime still requires proof of both the physical act and a specific mental state and purpose, and first-degree premeditated murder still requires proof the defendant caused death and intended and premeditated the killing — but now expert testimony can be offered to negate that intent element.
Immediate Fallout in an Oakland County Murder Case
The ruling did not stay confined to Ottawa County. In Oakland County, Deputy Chief Public Defender Lindsay Abramson filed a notice of diminished capacity for 18-year-old Stephan Larryl Shaw, who along with co-defendant Dshaun Omar Hatton-Street was charged in February in the death of 19-year-old Andre Sontay Avant Jr. Avant was found dead on February 16 in a car at Proud Lake Recreation Area in Commerce Township, having died from a gunshot wound to the head, according to CBS News Detroit. Shaw is charged with open murder and using a firearm in the commission of a felony.
Abramson's filing cites the Madison case directly and states the defense intends to introduce expert evidence of diminished capacity. She called the ruling a landmark decision that opens the door to potential acquittals in numerous cases, describing it as new ground for everyone, per The Oakland Press. She said the Michigan Supreme Court reached the right decision. A judge will ultimately decide whether the proposed diminished-capacity evidence should be admitted at Shaw's trial, and prosecutors retain the ability to challenge the defense with their own expert testimony.
The Oakland County Public Defender's Office says it anticipates filing additional diminished-capacity notices and is reviewing other pending cases for eligibility, though the office expects the defense to apply to only a very limited number of cases and says it will carefully screen which ones it selects. The Oakland County Prosecutor's Office declined to comment on the decision's anticipated effects.
What a Successful Claim Could Mean
The diminished capacity defense applies to defendants with severe mental health or cognitive issues that fall short of an insanity defense, which itself carries a very high burden requiring proof the defendant did not know right from wrong. Diminished capacity is described as a high standard that remains difficult to prove and requires supporting expert testimony about mental illness or cognitive defects. A successful finding could lead to a lesser charge such as involuntary manslaughter or second-degree homicide in some cases, or in others could support a full acquittal on a specific-intent crime.
Abramson expects a large amount of post-conviction litigation to follow, along with an influx of appeals from defendants who argue diminished capacity should have been available to them. She believes some Michigan Department of Corrections inmates may have been wrongfully incarcerated because that evidence was excluded under the old rule, and she hopes eligible cases will be reversed for new trials. She also expects evidentiary hearings challenging proposed defense evidence and expert testimony, along with additional case law to follow as courts work out how the new standard applies.
Courts Brace for a Slower, Costlier System
In a concurring opinion, Justice Noah Hood warned that restoring the diminished capacity defense will trigger widespread slowdowns in criminal cases and place immediate pressure on Michigan's already underfunded mental health infrastructure, per the Detroit Legal News. Courts, prosecutors, and public defender offices are expected to face a surge in pretrial notices, evidentiary hearings, and post-conviction appeals from state prisoners who were previously barred from introducing mental health evidence.
Following the July 31 ruling, the Michigan Supreme Court immediately published proposed amendments to the Michigan Court Rules to establish a standardized procedural framework for handling diminished-capacity filings in trial courts, aiming to give judges, prosecutors, and public defenders clear guidelines for expert notice and evidentiary hearings. Oakland County public defenders will receive training and a specific framework for handling potential diminished-capacity cases.
The pressure is expected to fall hardest on local mental health systems tasked with providing expert psychiatric evaluations for trial courts statewide. In Ottawa County, where the Madison case originated, voters approved a 10-year renewal of a 0.30-mill property tax levy this month to fund local mental health services, according to the Community Mental Health Association of Michigan — a local funding decision that arrives just as courts across the state brace for higher demand for psychiatric evaluations tied to the new legal landscape.
