Earlier this year, a state appellate court issued a written opinion in a Michigan homicide case discussing the lower court’s decision to exclude evidence of the defendant’s post-traumatic stress disorder (PTSD). Ultimately, the court determined that the lower court properly excluded the evidence and denied the defendant’s appeal.
The Facts of the Case
According to the court’s opinion, the defendant was involved in an altercation with the co-owner of an after-hours club. Evidently, the two men got into an argument earlier in the evening, and witnesses heard both men saying that they would return with a gun. The victim returned with a shotgun, that he held at his side as he locked up the club. The defendant also returned to the club. While no one saw what happened, it was uncontested that the victim was shot eight times. Later, the defendant admitted to shooting the victim.
At trial, the defendant attempted to present evidence that he had PTSD. PTSD is a mental health condition that stems from a traumatic event. Those who have PTSD can be triggered by certain events, sounds, sights, or feelings, bringing them back to the moment of the original trauma. Evidently, the defendant was the victim of a prior shooting, that left him with permanent brain damage. In the defense expert’s opinion, this affected the defendant’s ability to control his impulses when he felt threatened. The defendant intended on admitting the evidence to help establish his claim that he shot the victim in self-defense.
At trial, the prosecution filed a pretrial motion to exclude all evidence of the defendant’s PTSD. The trial court granted the prosecution’s motion, the jury convicted the defendant, and the defendant appealed.
The Court’s Analysis
The appellate court rejected the defendant’s argument on appeal, affirming the lower court’s decision to keep the evidence out of the jury’s consideration. The court began its analysis by noting that a claim of self-defense must be based on “an honest and reasonable belief of an imminent danger of death or great bodily harm.” The court then acknowledged that a defendant’s history could be relevant to a self-defense claim, however, the defense expert’s testimony was not relevant to the inquiry at hand. Specifically, the court explained that the defense expert’s opinion that the defendant’s PTSD impacted his impulse control when threatened did not speak to the defendant’s state of mind at the time of the shooting, and that the expert could not speak to the defendant’s state of mind based on the expert’s knowledge. The court noted that the expert could have, in theory, testified generally about PTSD; however, the defense did not offer this testimony.
Have You Been Accused of a Violent Crime?
If you have recently been accused of a violent crime, such as a Michigan assault offense, many defenses may apply to your case. At Michigan Defense Law, Attorney Paul J. Tafelski skillfully represents clients charged with all types of serious crimes. He maintains a network of respected expert witnesses that can be used in appropriate cases to establish the elements of crucial defenses. To learn more, and to schedule a free consultation with Attorney Tafelski today, call 248-451-2200 today.
