## Facts

- William L. Seefeld was charged with first-degree criminal sexual conduct arising from the rape of his younger sister.
- Seefeld entered a plea of guilty but mentally ill under Michigan law.
- The governing statute required the trial court, before accepting such a plea, to review reports of mental examinations, hold a hearing on mental illness at the time of the offense, and make an on-the-record finding that the defendant was mentally ill when the offense occurred.
- No psychiatric or psychological evaluation was obtained, no mental-health reports were placed in the record, and no hearing was held to determine whether Seefeld was mentally ill at the time of the offense.
- Before sentencing, defense counsel moved for a continuance to obtain a psychological examination; the trial court denied the motion.
- The trial court sentenced Seefeld to imprisonment for five to fifteen years.

## Issues

1. Whether a guilty-but-mentally-ill plea is valid when the trial court accepted it without obtaining mental-health evaluations, placing examination reports on the record, or holding a hearing and making findings on mental illness at the time of the offense as required by statute.
2. Whether the trial court erred by denying a continuance sought to obtain a psychological examination before sentencing.

## Decision

- The Michigan Court of Appeals vacated (set aside) Seefeld’s guilty-but-mentally-ill plea and remanded for further proceedings.
- The court held that the statutory prerequisites for accepting a guilty-but-mentally-ill plea were not satisfied because no examinations or reports existed in the record and no required hearing and finding occurred.
- The court treated the denial of a continuance as significant in light of the statutory scheme because proceeding without an evaluation ensured noncompliance with the mandatory safeguards.

## Legal Principles

- Statutory safeguards governing acceptance of a guilty-but-mentally-ill plea are mandatory.
- Before accepting a guilty-but-mentally-ill plea, the trial court must ensure a qualified mental-health examination occurs, review written reports of that examination, conduct a hearing addressing mental illness at the time of the offense, and make an explicit on-the-record finding that the defendant was mentally ill when the offense was committed.
- A guilty-but-mentally-ill plea accepted without the required examination, reports, hearing, and findings is invalid and must be set aside.

## Conclusion

The court vacated the guilty-but-mentally-ill plea because the trial court accepted it without the examinations, record reports, hearing, and on-the-record findings required by Michigan’s guilty-but-mentally-ill statute, and remanded for proceedings consistent with those requirements.


People v. Seefeld, 95 Mich. App. 197, 290 N.W.2d 123 (Mich. Ct. App. 1980)