People of Michigan v. Theodore Paul Wafer

Summary

The Court held that imposing punishments for both second-degree murder and statutory involuntary manslaughter arising from a single homicide violates the multiple-punishments strand of double jeopardy. The statutory requirement of malice for second-degree murder and the specification that statutory involuntary manslaughter occur without malice clearly demonstrate legislative intent to prohibit cumulative punishment, even though absence of malice is not an element the prosecution must prove. The Court reversed the Court of Appeals, vacated the manslaughter conviction, and remanded for resentencing.