People of Michigan v. Christopher Lehman Tadgerson

Summary

The Michigan Supreme Court held that being a prisoner in possession of a controlled substance is not plainly a strict-liability offense under the governing statutes. Because the statute neither specifies culpability nor plainly imposes strict liability, the default mens rea provision applies and requires proof of intent, knowledge, or recklessness, with recklessness serving as the minimum applicable standard here. The Court reversed the Court of Appeals and remanded for further proceedings because defendant's no-contest plea was based on the erroneous strict-liability ruling.