Michigan v. Fackelman
Annotate this CaseDefendant Charles Fackelman was found guilty but mentally ill of home invasion, felonious assault, and felony-firearm charges that resulted from an altercation he had with a man Defendant believed caused the death of his teenage son in an episode of "road rage." Defendant perceived the man to have been unremorseful about his role in the tragedy and antagonistic toward Defendant and his family during subsequent legal proceedings. The issue at Defendant's trial was whether he was legally insane at the time of the incident. The prosecution's expert opined that he was not, while Defendant's expert opined that he was. These experts were the only doctors who testified at trial but were not the only expert opinions before the jury. The jury was repeatedly told about a third expert diagnosis whose report was reviewed by the other experts, but was "conspicuously absent" from trial. This third expert's report was never admitted into evidence for the jury's review. Upon review of the trial record and the briefs submitted by the parties, the Supreme Court concluded that use of the "tie breaking" diagnosis as substantive evidence of Defendant's sanity compromised his constitutional right to be confronted with the witnesses against him. The Court reversed the judgment of the lower courts, vacated Defendant's convictions, and remanded the case for further proceedings.
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