People of Michigan v. Theresa Marie Gafken

Summary

The Court held that a defendant charged with second-degree murder under a depraved-heart theory may assert the common-law affirmative defense of duress. Because the trial court excluded evidence of the alleged threat and barred the defense, leaving the defendant without a meaningful defense, the constitutional error was not harmless. The Court reversed the Court of Appeals, vacated the conviction, and remanded for further proceedings.