## Facts

- Bruce Ramsey was charged with first-degree murder for killing his wife by choking her and stabbing her 32 times.
- Ramsey raised an insanity defense and moved to bar Michigan’s “guilty but mentally ill” (GBMI) verdict statute from consideration as unconstitutional; the motion was denied.
- Ramsey elected a bench trial and was found guilty but mentally ill of second-degree murder.
- Gary Boyd, in a consolidated appeal on the shared constitutional issue, was tried by jury for armed robbery and related offenses, raised insanity, and was found guilty but mentally ill.
- Psychiatric evidence in both cases addressed mental illness and whether each defendant met Michigan’s legal test for insanity.
- The Michigan Court of Appeals affirmed both convictions; the Michigan Supreme Court granted review to decide the constitutionality of the GBMI verdict statute.

## Issues

1. Whether Michigan’s GBMI verdict statute violates due process by encouraging compromise verdicts between guilt and not guilty by reason of insanity.
2. Whether the statute impermissibly confuses or dilutes the legal insanity determination by blurring “mental illness” and “insanity.”
3. Whether presenting GBMI to the factfinder improperly injects dispositional considerations outside the proper role of determining guilt and legal insanity.

## Decision

- The Michigan Supreme Court held the GBMI statute constitutional and rejected the due process challenges.
- The Court concluded that GBMI requires distinct findings: the defendant committed the offense, was mentally ill at the time, and was not legally insane.
- The Court characterized claims of “compromise verdict” effects as speculative and insufficient to establish a due process violation.
- The Court affirmed the judgments below and upheld the GBMI convictions in both Ramsey’s and Boyd’s cases.

## Legal Principles

- A GBMI verdict is constitutionally permissible when it is available only after the factfinder determines guilt and finds that legal insanity was not proven.
- Due process is not violated merely because an additional verdict option exists; multiple verdict options do not, by themselves, establish an unconstitutional risk of compromise.
- Legislative creation of verdict categories addressing mental illness, while preserving the existing legal insanity standard, does not deny a fair trial where the elements of the offense and the insanity standard remain governing questions for the factfinder.
- A mental-illness classification attached to a valid conviction does not violate due process where it does not alter the prosecution’s burden to prove guilt beyond a reasonable doubt or the governing standard for legal insanity.

## Conclusion

The Michigan Supreme Court upheld Michigan’s GBMI statute against due process attacks, reasoning that GBMI preserves the traditional insanity framework by requiring findings of guilt, mental illness, and absence of legal insanity, and it affirmed the GBMI convictions entered against Ramsey and Boyd.


People v. Ramsey, 422 Mich. 500, 375 N.W.2d 297 (1985)