## Facts

- In July 1995, James A. Carpenter went to Audrey Thomas’s home in Saginaw, Michigan, demanded entry, and asserted Thomas was “his woman.”
- After Thomas refused, Carpenter entered by crashing through a window.
- Carpenter produced a handgun and fired two shots inside the house.
- He struck Aron Blakely and hit Thomas with the butt of the handgun, then left the scene.
- Police surrounded Carpenter’s residence; during negotiations he made statements about “demons” and claimed money had been stolen.
- At a bench trial, Carpenter offered expert testimony that mental illness and drug-related organic brain damage impaired him and that he heard voices, contending he lacked the specific intent for first-degree home invasion and felonious assault.
- The prosecution offered expert testimony that Carpenter was not psychotic and that his conduct was purposeful and goal-directed.

## Issues

1. Whether Michigan law permits a defendant to introduce evidence of mental abnormality short of statutory insanity to negate specific intent (a “diminished capacity” defense) in light of Michigan’s statutory scheme addressing mental illness and mental retardation defenses.
2. Whether excluding diminished-capacity evidence violates due process where the state provides a comprehensive insanity framework.

## Decision

- The Michigan Supreme Court affirmed the Court of Appeals and upheld Carpenter’s convictions for first-degree home invasion and felonious assault.
- The Court held Michigan’s comprehensive statutory scheme governing insanity and related verdicts reflects legislative intent to preclude diminished capacity as an independent defense to negate specific intent.
- The Court rejected the argument that due process requires admission of diminished-capacity evidence apart from the statutory insanity framework.

## Legal Principles

- When the Legislature enacts a comprehensive statutory scheme governing criminal responsibility based on mental illness or mental retardation, courts should not recognize a conflicting common-law diminished-capacity doctrine.
- In Michigan, evidence of mental abnormality short of statutory insanity is not admissible to avoid or reduce criminal responsibility by negating specific intent through a diminished-capacity defense.
- The statutory options—insanity (MCL 768.21a) and guilty but mentally ill (MCL 768.36)—define the permissible mental-condition defenses and related outcomes.
- Due process is not violated by a state’s decision to limit or exclude diminished-capacity evidence so long as the state provides a rational insanity framework for mental-condition defenses.

## Conclusion

Michigan does not recognize diminished capacity as a defense to negate specific intent; mental-condition evidence may affect criminal responsibility only through the statutory insanity and guilty-but-mentally-ill framework, and Carpenter’s convictions were therefore affirmed.


People v. Carpenter, 464 Mich. 223, 627 N.W.2d 276 (Mich. 2001)