Michigan Supreme Court Decisions
The Michigan Supreme Court recently issued an important decision addressing the proper role of expert witnesses in criminal trials. In People v. Alexander, the Court examined whether a child abuse pediatrician’s testimony diagnosing a child with “medical torture” was admissible when the defendant was charged with the crime of torture. The decision guides the limits of expert testimony and reinforces the principle that determining criminal guilt remains the jury’s responsibility.
At The Kronzek Firm, our attorneys have more than 30 years of experience following Michigan Supreme Court decisions and helping clients understand how appellate rulings shape Michigan law. This opinion highlights the careful balance courts must maintain between expert medical testimony and the jury’s role in deciding criminal responsibility.
The Supreme Court’s Analysis
The Court concluded that the expert’s testimony diagnosing the child with “medical torture” should not have been admitted under Michigan Rule of Evidence 702. According to the Court, the diagnosis did not help the jury determine a fact in issue, lacked a reliable foundation regarding its psychological component, and risked invading the province of the jury by using terminology closely associated with the criminal charge itself.
The Court explained that expert testimony may assist jurors in understanding medical evidence, such as the nature, timing, or mechanism of an injury. However, it distinguished those permissible opinions from testimony that could be interpreted as expressing a view on a defendant’s criminal responsibility. The Court also discussed its reasoning alongside the principles previously addressed in People v. McFarlane, concluding that the phrase “medical torture” created a substantial risk of confusing a medical diagnosis with the legal determination reserved for the jury.
Why the Convictions Were Upheld
Although the Michigan Supreme Court found that admitting the “medical torture” diagnosis was erroneous, it ultimately affirmed the defendant’s convictions. Because no objection had been made at trial, the Court reviewed the issue under the plain-error standard.
The Court determined that the remaining evidence—including testimony regarding the child’s injuries, testimony from the child and another witness about the restraints, and the defendant’s own admissions to police—provided strong, properly admitted evidence supporting the convictions. As a result, the Court concluded that the evidentiary error did not affect the outcome of the proceedings and did not warrant reversal.
This Michigan Supreme Court decision serves as a reminder that while expert witnesses can provide valuable medical opinions, their testimony must remain within the limits established by Michigan’s rules of evidence. Courts will continue to carefully distinguish between testimony that helps jurors understand technical evidence and testimony that risks influencing the jury’s ultimate determination of guilt.