People of Michigan v. Milton Lee Lemons

Summary

The Court held that the trial court abused its discretion under MRE 702 by excluding defense expert testimony challenging whether abusive shaking could have caused the child's injuries. The Court further held that the changed opinion of the prosecution's former medical examiner, together with the admissible defense expert evidence and alternative-causation theory, satisfied the requirements for relief based on newly discovered evidence because a different result was probable on retrial. The conviction was therefore reversed and the case remanded for a new trial.