People v. Nelson (Michigan 2025)

In People v. Nelson, the defendant was convicted of felonious assault, domestic violence, and possession of a firearm during the commission of a felony. At trial, the Court barred the defendant from testifying that her partner had threatened to kill her; this testimony was central to her self-defense claim. On appeal, the prosecution conceded the exclusion was erroneous, but the Court of Appeals affirmed the conviction after determining the error was not outcome determinative. The Michigan Supreme Court reversed and remanded for a new trial. The Court held that the improper exclusion of the testimony was more likely than not outcome determinative under the harmless-error rule established in People v. Lukity, 460 Mich. 484, 596 N.W.2d 607 (1999), because the threat was a key element of the defendant’s claim of self-defense.