Diminished-capacity defense; People v Carpenter; Ineffective assistance of counsel; Failure to advance a meritless argument

The court held that the trial court did not err in preventing defendant-Jones “from presenting a diminished-capacity defense to negate the specific-intent element of the charges against him.” He was convicted of first-degree murder, felony murder, first-degree home invasion, AWIM, unlawful imprisonment, FIP, and felony-firearm. He contended on appeal that “he should have been able to present a diminished-capacity defense” based on his long-term meth use despite the Michigan Supreme Court’s decision in Carpenter, which he asserted was wrongly decided. He further contended his trial counsel was ineffective for “failing to hire and call an expert who could have testified about his diminished capacity.” The court noted it was bound by stare decisis to follow the Michigan Supreme Court’s decisions and only “the Supreme Court has the authority to overrule its previous decisions.” As to his ineffective assistance claim, under “Carpenter, Jones would only be able to present evidence to challenge whether he had the mental capacity to form the specific intent if he met the definition of legal insanity. The record evidence showed that Jones did not meet the statutory definition of legal insanity at the time that he committed the acts at issue. For that reason, his lawyer could reasonably conclude that the defense of insanity was not available to Jones.” In addition, given that the Michigan “Supreme Court abolished the diminished-capacity defense, Jones’s lawyer cannot be faulted for failing to hire an expert and attempting to present a defense that contradicted Michigan law.” Affirmed.