People v. Warner (Michigan 2024)

In People v. Warner, 514 Mich. 41, 22 N.W.3d 1 (2024), the defendant was convicted of first-degree criminal sexual conduct against his minor stepdaughter. He was interrogated by law enforcement three times, initially maintaining his innocence before signing a confession prepared by the police. At trial, the defense requested public funds to hire an expert witness on false confessions to challenge the reliability of the confession. The trial court denied the request, and the Eaton Circuit Court affirmed the conviction on appeal. The Michigan Supreme Court reversed and remanded for further proceedings. It held that the denial of funds to obtain a false confession expert deprived the defendant of a fair trial because the confession was central to the prosecution’s case. The Court emphasized that when a confession forms the core of the evidence against a defendant, fundamental fairness requires that the defense have a meaningful opportunity to challenge its credibility through expert testimony if requested.

Topics

• Sexual violence and rape
• Statutory rape or defilement

Geographical location

• North America
• United States
• Michigan

Keywords

• criminal law and procedure
• child abuse
• expert witnesses
• coerced confessions

Year

• 2024

External URL

• People v. Warner (Michigan 2024)

Court

• Supreme Court of Michigan

Type

• Domestic Case Law

Jurisdiction

• Michigan